REPORT TO CONGRESS
DISPOSAL OF HAZARDOUS WASTES
This publication (SW-115) was prepared
by the OFFICE OF SOLID WASTE MANAGEMENT PROGRAMS
as required by Section 212 of The Solid Waste Disposal Act as amended
and was delivered June 30, 1973, to the President and the Congress
U.S. ENVIRONMENTAL PROTECTION AGENCY
1974
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An environmental protection publication
in the solid waste management series (SW-115)
>
r
For sale by the Superintendent ot Documents, U.S. Government Printing Office, Washington, D.C. 20402 - Price $1.55
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FOREWORD
Section 212 of the Solid Waste Disposal Act (P.L. 89-272) as amended
required that the U.S. Environmental Protection Agency (EPA) undertake a
comprehensive investigation of the storage and disposal of hazardous wastes.
This document represents EPA's Report to the President and the Congress
summarizing the Agency's investigations and recommendations in response to
the congressional mandate. The findings are based on a number of contractual
efforts and analyses by Agency staff carried out since the passage of the
Resource Recovery Act of 1970.
The report is organized into a summary, five major sections, and
appendixes. The first section discusses the congressional mandate and the
Agency's response to it. Next, the public health, technological, and economic
aspects of the problem of disposing of hazardous wastes are reviewed. A section
detailing the case for hazardous waste regulation follows. The report concludes
with a discussion of implementation issues and a presentation of findings and
recommendations.
Although there have been minor editorial revisions, this publication is
essentially the same as that delivered on June 30, 1973, to Congress, except that
the references have been reverified and revised accordingly. Also, the report has
been typeset in a conventional style to improve its readability.
-ARSEN J. DARNAY
Deputy Assistant Administrator
for Solid Waste Management
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CONTENTS
PAGE
Summary and Conclusions ix
1, Introduction 1
THE CONGRESSIONAL MANDATE . 1
THE EPA RESPONSE . 1
First Study 1
Second Study 1
Third Study 2
Fourth Study 2
Fifth Study . 2
Strategy Analysis .... 2
2. Identification and Discussion of the Problem 3
THE NATURE OF HAZARDOUS WASTES . . 3
Toxic Chemical Wastes 4
Biological Wastes 6
Radioactive Wastes . . . 6
FACTORS INFLUENCING THE GROWTH OF HAZARDOUS WASTES . 7
PUBLIC HEALTH AND ENVIRONMENTAL EFFECTS ... 7
PRESENT TREATMENT AND DISPOSAL TECHNOLOGY ... 8
Public Use of Existing Technology . . 11
Private Use of Existing Technology ... ... 11
The Hazardous Waste Processing Industry ... 11
ECONOMIC INCENTIVES 11
SUMMARY 12
5. The Case for Hazardous Waste Regulations 15
EXISTING AUTHORITIES FOR HAZARDOUS WASTE
MANAGEMENT 15
Federal Control Statutes ... . .... 15
State Control Statutes .... 17
Summary . .... . . 17
PRECEDENTS FOR HAZARDOUS WASTE REGULATION 17
The Clean Air Act 18
The Federal Water Pollution Control Act 18
CLOSING THE CIRCLE ON HAZARDOUS WASTES 20
Persons and Activities Subject to Regulatory Controls 20
Types of Hazardous Waste Standards 21
Strategies for Hazardous Waste Regulation . . 21
SUMMARY . . . ... . 23
4. Issues of Implementation 25
HAZARDOUS WASTE MANAGEMENT SYSTEM 25
Costs 26
Variations 27
COST DISTRIBUTION TO USERS 29
Equity of Cost Distribution 29
Analysis of Cost Impacts ... ... .... . 30
Benefit/Cost Analysis 30
ROLE OF THE PRIVATE SECTOR 30
Capacity Creation . . . . . 31
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VI DISPOSAL OF HAZARDOUS WASTES
PAGE
Environmentally Sound Operation 33
Reasonable User Charges 34
Long-Term Care 34
ROLE OF GOVERNMENT 35
Performance Bonding 35
Financial Assistance 36
Economic Regulation 37
Use of Federal or State Land 37
Government Ownership and Operation of Facilities 37
SUMMARY 38
5 . Findings and Recommendations 39
FINDINGS 39
RECOMMENDATIONS 40
Appendix A -Impact of Improper Hazardous Waste Manage-
ment on the Environment 41
WASTE DISCHARGE HAZARDS 41
Improper Arsenic Disposal 41
Lead Waste Hazard 41
Cyanide and Phenol Disposal 41
Arsenic Contamination 42
Insecticide Dumping 42
Trace Phenol Discharge 42
Discharge of Hydrocarbon Gases Into River 42
Cyanide Discharge 42
Arsenic Dump: Groundwater Contamination 42
Poisoning of Local Water Supply 43
MISMANAGEMENT OF WASTE MATERIALS 43
Fish Kill 43
Phosphate Slime Spill 43
Mismanagement of Heterogeneous Hazardous Waste 43
Arsenic Waste Mishap 44
Contaminated Grain 44
Radioactive Waste 44
Waste Stockpiling Hazard: Two Cases 44
Chlorine Holding Pond Breach 44
Malpractice Hazard 44
Explosive Waste 44
Unidentified Toxic Wastes 44
Container Reclamation 45
Stockpiling of Hazardous Waste 45
Pesticides in Abandoned Factory 45
Groundwater Contamination by Chromium- and Zinc-Containing
Sludge 45
Disposal of Chromium Ore Residues 45
Dumping of Cadmium-Containing Effluents Into the Hudson
River 45
Pesticide Poisoning 45
Improper Disposal of Aldrin-Treated Seed and Containers ... 45
Improper Pesticide Container Disposal 46
Ocean Dumping of Chemical Waste 46
RADIOACTIVE WASTE DISPOSAL 46
National Reactor Testing Station 46
Decommissioning of AEG Plant 46
Nuclear Waste Disposal 46
Appendix B-Hazardous Waste Stream Data 47
Appendix C-Decision Model for Screening and Selecting
Hazardous Compounds and Ranking Hazardous Wastes . . 55
DEFINITIONS OF ABBREVIATIONS USED IN THE SCREENING
MODEL 55
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CONTENTS Vll
PAGE
CRITERIA FOR SCREENING AND SELECTION 56
PRIORITY RANKING OF WASTES 56
Appendix D-Summary of Hazardous Waste Treatment and
Disposal Processes 59
PHYSICAL TREATMENT 60
CHEMICAL TREATMENT 61
THERMAL TREATMENT 62
BIOLOGICAL TREATMENT . . - 62
ULTIMATE DISPOSAL 63
-Appendix E-Decision Maps for On-Site Versus Off-Site
Treatment and Disposal 65
Appendix F—Summary of the Hazardous Waste National
Disposal Site Concept 71
SITING OF HAZARDOUS WASTE TREATMENT AND DISPOSAL
FACILITIES 71
HAZARDOUS WASTE MANAGEMENT METHODS AND COSTS . . 75
DESCRIPTION OF MODEL FACILITIES 76
Hazardous Waste Processing Facility .... 76
Hazardous Waste Disposal Facility 77
Process Selection 77
Cost Estimates 78
Appendix G-Proposed Hazardous Waste Management
Act of 1973 83
References 109
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SUMMARY AND CONCLUSIONS
The management of the Nation's hazardous residues-toxic chemical,
biological, radioactive, flammable, and explosive wastes-is generally inadequate;
numerous case studies demonstrate that public health and welfare are
unnecessarily threatened by the uncontrolled discharge of such waste materials
into the environment.
From surveys conducted during this program, it is estimated that the
generation of nonradioactive hazardous wastes is taking place at the rate of
approximately 10 million tons yearly.1 About 40 percent of these wastes by
weight is inorganic material and about 60 percent is organic; about 90 percent
occurs in liquid or semiliquid form.
Hazardous waste generation is growing at a rate of 5 to 10 percent
annually as a result of a number of factors: increasing production and
consumption rates, bans and cancellations of toxic substances, and energy
requirements (which lead to radioactive waste generation at higher rates).
Hazardous waste disposal to the land is increasing as a result of air and
water pollution controls (which capture hazardous wastes from other media and
transfer them to land) and denial of heretofore accepted methods of disposal
such as ocean dumping.2
Current expenditures by generators for treatment and disposal of such
wastes are low relative to what is required for adequate treatment and disposal.
Ocean dumping and simple land disposal costs are on the order of $3 per ton
whereas environmentally adequate management could require as much as $60
per ton if all costs are internalized.3
Federal, State, and local legislation and regulations dealing with the
treatment and disposal of nonradioactive hazardous waste are generally spotty or
nonexistent. At the Federal level, the Clean Air Act; the Federal Water Pollution
Control Act; and the Marine Protection, Research, and Sanctuaries Act provide
control authority over the incineration, and water and ocean disposal of certain
hazardous wastes but not over the land disposal of residues. Fourteen other
Federal laws deal in a peripheral manner with the management of hazardous
wastes. Approximately 25 States have limited hazardous waste regulatory
authority.
Given this permissive legislative climate, generators of waste are under
little or no pressure to expend resources for the adequate management of their
hazardous wastes. There is little economic incentive (e.g., the high costs of
adequate management compared with costs of current practice) for generators to
dispose of wastes in adequate ways.
Technology is available to treat most hazardous waste streams by physical,
chemical, thermal, and biological methods, and for disposal of residues. Use of
such treatment and disposal processes is costly, ranging from a low of $1 40 per
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DISPOSAL OF HAZARDOUS WASTES
ton for carbon sorption, $10 per ton for neutralization/precipitation, and
$13.60 per ton for chemical oxidation to $95 per ton for incineration.4 Several
unit processes are usually required for complete treatment and disposal of a
given waste stream. Transfer and adaptation of existing technology to hazardous
waste management may be necessary in some cases. Development of new
treatment and disposal methods for some wastes (e.g., arsenic trioxide and
arsenites and arsenates of lead, sodium, zinc, and potassium) is required.5 In the
absence of treatment processes, interim storage of wastes on land is possible
using methods that minimize hazard to the public and the environment (e.g.,
secure storage and membrane landfills).
A small private hazardous waste management industry has emerged in the
last decade, offering treatment and disposal services to generators. The industry
currently has capital investments of approximately $25 million and a capacity to
handle about 2.5 million tons of hazardous materials yearly, or 25 percent of
capacity required nationally. However, the industry's current throughput of
hazardous waste is about 24 percent of installed capacity, or 6 percent of the
national total. The low level of utilization of this industry's services results from
the absence of regulatory and economic incentives for generators to manage
their hazardous wastes in an environmentally sound manner. This industry could
respond over time to provide needed capacity if a national program for
hazardous waste management, with strong enforcement capabilities, was created.
This industry would, of course, be subject to regulation also.
The chief programmatic requirement to bring about adequate management
of hazardous wastes is the creation of demand and adequate capacity for
treatment and disposal of hazardous wastes. A national policy on hazardous
waste management should take into consideration environmental protection,
equitable cost distribution among generators, and recovery of waste materials.
A regulatory approach is best for the achievement of hazardous waste
management objectives. Such an approach ensures adequate protection of public
health and the environment. It will likely result in the creation of treatment and
disposal capacity by the private sector without public funding. It will result in
the mandatory use of such facilities. Costs of management will be borne by
those who generate the hazardous wastes and their customers rather than the
public at large; thus, cost distribution will be equitable. Private sector
management of the wastes in a competitive situation can lead to an appropriate
mix of source reduction, treatment, resource recovery, and land disposal.
A regulatory program will not directly create a prescribed system of
national disposal sites because of uncertainties inherent in the private sector
response. EPA believes that the private sector will respond to a regulatory
program. However, full assurance cannot be given that treatment and disposal
facilities will be available in a timely manner for all regions of the Nation nor
that facility use charges will be reasonable in relation to cost of services. Also,
private enterprise does not appear well suited institutionally to long-term
security and surveillance of hazardous waste storage and disposal sites.
Given analyses performed to date, EPA believes that no Government
actions to limit the uncertainties in private sector response are appropriate at
this time. However, if private capital flow was very slow and adverse
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SUMMARY AND CONCLUSIONS xi
environmental effects were resulting from the investment rate, indirect financial
assistance in forms such as loans, loan guarantees, or investment credits could be
used to accelerate investment. If facility location or user charge problems arose,
the Government could impose a franchise system with territorial limits and user
charge rate controls. Long-term care of hazardous waste storage and disposal
facilities could be assured by mandating use of Federal or State land for such
facilities.
EPA studies indicate that treatment and disposal of hazardous wastes at
central processing facilities are preferable to management at each point of
generation, in most cases, because of economies of scale, decreased environ-
mental risk, and increased opportunities for resource recovery. However, other
forces may deter creation of the "regional processing facility" type of system.
For example, the pending effluent limitation guidelines now being developed
under authority of the Federal Water Pollution Control Act may force each
generator to install water treatment facilities for both hazardous and nonhazard-
ous aqueous waste streams, Consequently, the absolute volume of hazardous
wastes requiring further treatment at central facilities may be reduced and the
potential for economies of scale at such facilities may not be as strong as it is
currently.
Given these uncertainties, several projections of future events can be made.
Processing capacity required nationally was estimated assuming complete
regulation, treatment, and disposal of aJJ hazardous wastes at the earliest
practicable time period. Estimates were based on a postulated scenario in which
approximately 20 regional treatment and disposal facilities are constructed
across the Nation. Of these, 5 would be very large facilities serving major
industrial areas, each treating 1.3 million tons annually, and 15 would be
medium-size facilities, each treating 160,000 tons annually. An estimated 8.5
million tons of hazardous wastes would be treated and disposed of away from
the point of generation (off site); 1.5 million tons would be pretreated by
generators on site, with 0.5 million tons of residues transported to off-site
treatment and disposal facilities for further processing. Each regional processing
facility was assumed to provide a complete range of treatment processes capable
of handling all types of hazardous wastes; and, therefore, each would be much
more costly than existing private facilities.
Capital requirements to create the system described are approximately
$940 million. Average annual operating expenditures (including capital recovery
and operating costs) of $620 million would be required to sustain the program.
These costs are roughly estimated to be equivalent to 1 percent of the value of
shipments from industries directly impacted. In addition, administrative ex-
penses of about $20 million annually for Federal and State regulatory programs
would be necessary. For the reasons stated earlier, however, capacity and capital
requirements for a national hazardous waste management system may be smaller
than indicated, and more in line with the capacity and capital availability of the
existing hazardous waste management industry.
In summary, the conclusions of the study are that (1) a hazardous waste
management problem exists and its magnitude is increasing; (2) the technical
means to solve the problem exist for most hazardous waste but are costly in
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xii DISPOSAL OF HAZARDOUS WASTES
comparison with present practices; (3) the legislative and economic incentives
for using available technology are not sufficient to cause environmentally
adequate treatment and disposal in most cases; (4) the most effective solution at
least direct cost to the public is a program for the regulation of hazardous waste
treatment and disposal; (5) a private hazardous waste management service
industry exists and is capable of expanding under the stimulus of a regulatory
program; (6) because of inherent uncertainties, private sector response cannot be
definitely prescribed; (7) several alternatives for Government action are
available, but, based on analyses to date, EPA is not convinced that such actions
are needed.
EPA has proposed legislation to the Congress that is intended both to
fulfill the purposes of Section 212 of the Solid Waste Disposal Act as amended
and to carry out the recommendations of this report. The proposed Hazardous
Waste Management Act of 1973 would authorize a regulatory program for
treatment and disposal of EPA-designated hazardous wastes; the States would
implement the program subject to Federal standards in most cases. All studies
performed in response to Section 212 will be completed in time to serve as
useful input to congressional consideration of our legislative proposal.
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DISPOSAL OF HAZARDOUS WASTES
Section 1
THE CONGRESSIONAL MANDATE
In 1970, Congress perceived hazardous waste
storage and disposal to be a problem of national
concern. Section 212 of the Resource Recovery Act
of 1970 (P.L. 91-512-an amendment to P.L.
89-272), enacted on October 26, 1970, required that
EPA prepare a comprehensive report to Congress on
storage and disposal of hazardous wastes. That
section stated the following:
The Secretary [*] shall submit to the Congress no later than
two years [t] after the date of enactment of the Resource
Recovery Act of 1970 a comprehensive report and plan for
the creation of a system of national disposal sites for the
storage and disposal of hazardous wastes, including radio-
active, toxic chemical, biological, and other wastes which
may endanger public health or welfare. Such report shall
include: (1) a list of materials which should be subject to
disposal at any such site; (2) current methods of disposal of
such materials; (3) recommended methods of reduction,
neutralization, recovery or disposal of such materials; (4) an
inventory of possible sites including existing land or water
disposal sites operated or licensed by Federal agencies; (5) an
estimate of the cost of developing and maintaining sites
including consideration of means for distributing the short-
and long-term costs of operating such sites among the users
thereof; and (6) such other information as may be
appropriate.
THE EPA RESPONSE
This document represents EPA's Report to the
President and the Congress summarizing the Agency's
investigations and recommendations concerning
hazardous wastes in response to the congressional
mandate. All information required by the mandate is
included in the report and its appendixes. This report
provides a definition of current status, issues, and
options. It does not purport to provide a complete
*The Secretary of Health, Education, and Welfare.
Reorganization Plan Number 3 of 1970 transferred authority
to the Administrator, EPA.
'EPA requested and received a time extension for
submission of this report until June 30, 1973, because
appropriation of funds to implement the Resource Recovery
Act of 1970 was delayed for 8 months after enactment.
solution to the hazardous waste management prob-
lem.
Section 212 requires an evaluation of a system of
national disposal sites (NDS's) for the storage and
disposal of hazardous wastes as a solution to the
hazardous waste problem. To evaluate the NDS
concept properly, it is necessary to view it in the
context of the total problem. On probing the
problem, EPA determined that several means of
accomplishing the NDS objective exist. To provide
the Congress with maximum flexibility of action,
EPA elected to investigate and evaluate several
alternative solutions. A series of interrelated contrac-
tor and in-house studies was undertaken for the
specific purpose of complying with Section 212 of
the Resource Recovery Act of 1970.
First Study
The first study, upon which subsequent efforts
were based, quantified the hazardous waste prob-
lem.6 From a thorough literature survey and contacts
with various trade and technical associations, Govern-
ment agencies, and industry, a list of hazardous
materials was compiled, and each candidate substance
on this list was rated according to the nature and
severity of its hazardous properties. In addition,
volume and distribution data (both by geography and
by industry groups) were gathered, and current
hazardous waste handling and disposal practices were
surveyed. It was found that the magnitude of the
hazardous waste problem was larger than originally
anticipated and that current disposal practices are
generally inadequate.
Second Study
Next, a more detailed technical study on the
properties of these materials and their treatment and
disposal methods was conducted.7 A "profile report"
was written on each listed substance summarizing its
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DISPOSAL OF HAZARDOUS WASTES
physical, chemical, and toxicological properties; its
industrial uses; and the hazards associated with
proper handling and disposal methods. Each profile
report incorporated a critical evaluation of currently
used and available technology for the handling,
storage, transport, neutralization, detoxification, re-
use, and disposal of the particular substance. Also,
advanced methods of hazardous waste treatment were
surveyed, and research and development needs were
formulated. The study showed that treatment and
disposal technology is available for most hazardous
wastes.
Third Study
A favorable public attitude is essential for the
successful implementation of any nationwide hazard-
ous waste management program. Therefore, a third
study was undertaken to determine citizen awareness
and attitudes regarding the hazardous waste problem
and reaction to the possibility of having a treatment
and disposal facility located in the vicinity.8 The
majority of citizens sampled were found to be in
favor of regional processing facilities for hazardous
wastes since such facilities would increase environ-
mental protection and stimulate the economy of the
region.
Fourth Study
A fourth study analyzed and compared alternative
methods of hazardous waste management.9 It was
concluded that there are three basic approaches: (1)
process hazardous wastes "on site" (i.e., at the plant
where they are generated); (2) process "off site" at
some regional facility (either public or private); (3)
combine on-site pretreatment with off-site treatment
and disposal. These basic alternatives were evaluated
with respect to economics, risk, and legal and
institutional issues. The study indicated that option
(2) is preferable for most hazardous waste streams
and option (3) is preferable for dilute aqueous toxic
metal wastes.*
Fifth Study
A fifth comprehensive study examined the feasibil-
ity of an NDS system for hazardous wastes.' °
Potential locations for regional processing and dis-
posal sites were identified. Conceptual designs of
hazardous waste treatment and disposal facilities were
developed, based on multicomponent waste streams
characteristic of industry. Capital and operational
cost estimates were made, and funding and cost
distribution mechanisms were examined.
Strategy Analysis
Lastly, a strategy analysis was performed, based on
information from the previous studies. It was con-
cluded that a regulatory program is the best approach
to the hazardous waste problem. The case for
hazardous waste regulation is discussed in Section 3.
Issues of implementation are evaluated in Section 4,
and findings and recommendations are given in
Section 5. A review of the hazardous waste disposal
problem precedes these discussions.
*In this report the term "waste stream" refers to mass
flow in the engineering process sense and not necessarily to a
liquid stream.
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Section 2
IDENTIFICATION AND DISCUSSION OF THE PROBLEM
Inadequate management of hazardous wastes has
the potential of causing adverse public health and
environmental impacts. These impacts are directly
attributable to the acute (short-range or immediate)
or chronic (long-range) effects of the associated
hazardous compound or combination of compounds,
and production quantities and distribution.11'12
Many cases document the imminent and long-term
danger to man or his environment from improper
disposal of such hazardous wastes. Three examples
follow.
Several people in Minnesota were hospitalized in
1972 after drinking well water contaminated by an
arsenic waste buried 30 years ago on nearby agricul-
tural land.
Since 1953, an Iowa company has dumped several
thousand cubic yards of arsenic-bearing wastes on a
site located above an aquifer supplying a city's water.
Arsenic content in nearby monitoring well samples
has been measured as high as 175 parts per million;
the U.S. Public Health Service drinking water stand-
ards recommend an arsenic content less than 0.05
part per million.
In Colorado, a number of farm cattle recently died
of cyanide poisoning caused by indiscriminate dis-
posal of cyanide-bearing wastes at a dump site
upstream. Additional case studies citing the effects of
hazardous waste mismanagement are given in Appen-
dix A.
Discussed in this section are the types, forms,
sources, and quantities of hazardous waste; the
current status of treatment and disposal technology;
and the economic incentives bearing on hazardous
waste treatment and disposal.
THE NATURE OF HAZARDOUS WASTES
The term "hazardous waste" means any waste or
combination of wastes which pose a substantial
present or potential hazard to human health or living
organisms because such wastes are lethal, nondegrada-
ble, or persistent in nature; may be biologically
magnified; or may otherwise cause or tend to cause
detrimental cumulative effects.13 General categories
of hazardous waste are toxic chemical, flammable,
radioactive, explosive, and biological. These wastes
can take the form of solids, sludges, liquids, or gases.
The sources of hazardous wastes are numerous and
widely scattered throughout the Nation. Sources
consist of industry, the Federal Government [mainly
the Atomic Energy Commission (AEC) and the
Department of Defense (DOD)], agriculture, and
various institutions such as hospitals and laboratories.
During this study, waste streams containing
hazardous compounds were identified and quantified
by industrial source (Appendix B). These waste
streams were selected by utilizing a decision model
(Appendix C) that is relatively unsophisticated com-
pared to that required for standard-setting pur-
poses.14 Therefore, the hazardous compounds and
waste streams cited in this report should be consid-
ered as illustrative and are not necessarily those that
should be regulated. From these data, the total
quantity of nonradioactive hazardous waste streams
generated by industrial sources in 1970 was estimated
to be 10 million tons (9 million metric tons), or
approximately 10 percent of the 110 million tons
(100 million metric tons) of all wastes generated by
industry annually.15 This quantity includes most
industrial wastes generated from contractor-operated
Government facilities.
Approximately 70 percent of industrial hazardous
wastes are generated in the mid-Atlantic, Great Lakes,
and Gulf Coast areas of the United States (Table 1).
About 90 percent by weight of industrial hazardous
wastes are generated in the form of liquid streams, of
which approximately 40 percent are inorganic and 60
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DISPOSAL OF HAZARDOUS WASTES
TABLE 1
ESTIMATED INDUSTRIAL HAZARDOUS WASTE GENERATION BY REGION* IN TONS PER YEAR (1970)t
New England
Mid Atlantic
East North Central
West North Central
South Atlantic
East South Central
West South Central
West (Pacific)
Mountain
Totals
Inorganics in aqueous
Tons
95,000
1,000,000
1.300,000
65,000
230,000
90,000
320,000
120,000
125,000
3,345,000
Metric tons
86,000
907,200
1,180,000
59,000
208,500
81,700
290,000
109,000
113.500
3,034,900
Organics in aqueous
Tons
170,000
1,100,000
850,000
260,000
600,000
385,000
1,450,000
550,000
5,000
5,370,000
Metric tons
154,000
1,000,000
770,000
236,000
545,000
350,000
1,315,000
500,000
4,540
4,874,540
Organics
Tons
33,000
105,000
145,000
49,500
75,000
44,000
180,000
113,000
50,000
794,500
Metric tons
30,000
90,600
132,000
45,000
68,000
40.000
163,000
103,000
45,400
717,000
Sludges,! slurries, solids
Tons
6,000
55,000
90,000
18,500
80,000
9,500
39,000
30,500
1 1 ,500
340,000
Metric tohs
5,450
50,000
81,600
16,800
72,600
8,600
35,400
27,770
10,400
308,620
Total
Tons
304,000
2,260,000
2,385,000
393,000
985,000
528,000
1,989,000
813,500
191,500
9,849,500
Metric tons
275,450
2,047,800
2,163,600
350,800
894,100
480,300
1,803,400
739,770
173,840
8,929,060
Percent
of total
3.1
22.9
24.2
4.0
10.0
5.4
20.2
8.3
1 9
1000
"Refers to Bureau of Census regions, as defined in Appendix B
'Source EPA Contract No. 68-01-0762.
•("Predominantly inorganic.
percent are organic materials. Representative hazard-
ous waste substances have been cross indexed by
industrial sources (Table 2). It is important to
recognize that these hazardous substances are constit-
uents of waste streams, and it is these waste streams
which require treatment, storage, and disposal.
Sources of radioactive wastes are nuclear power
generation and fuel reprocessing facilities; private
sources, such as medical, research and development,
and industrial laboratories; and Government sources
(AEC and DOD). Quantities of radioactive wastes
generated in 1970 from the first two sources were
identified (Table 3). Only a limited amount of
information is available on source material, special
nuclear material, or byproduct materials from
Government operations. Such information is related
to weapons production and is therefore classified.
Disposal of uranium mill tailings represents a
unique problem similar in magnitude to the disposal
of all industrial hazardous wastes. Several Federal
agencies are working on the problem at present; a
satisfactory disposal or recovery method has not yet
been defined. Aside from uranium mill tailings, the
quantity of radioactive wastes associated with the
commercial nuclear electric power industry and other
private sources is estimated to be approximately
24,000 tons (22,000 metric tons) per year at present,
or less than 1 percent of the total hazardous wastes
from all industry.
Toxic Chemical Wastes
Practically all of the estimated 10 million tons (9
million metric tons) of nonradioactive hazardous
waste generated annually in the United States falls
into the toxic category. In the context of this report
toxicity is defined as the ability of a waste to produce
injury upon contact with or accumulation in a
susceptible site in or on the body of a living organism.
Most toxic wastes belong to one or more of four
categories: inorganic toxic metals, salts, acids, or
bases; synthetic organics; flammables; and explosives.
There is considerable overlap within these waste
categories. For example, a synthetic organic waste
may be flammable and explosive, and it may also
contain toxic metals. Flammable and explosive wastes
are often categorized as separate hazardous waste
entities; however, they are generally toxic and will be
discussed here. Many radioactive and some biological
wastes are also toxic, but they will be discussed
separately.
Toxic Metals. Approximately 25 percent of the
metals in common usage today are toxic.'2 The
concentration and chemical form of toxic metals
determine their potential health and environmental
hazards. Some metals are essential to life at low
concentrations but are toxic at higher concentra-
tions.12'16 Also, a pure metal is usually not as
dangerous as a metallic compound (salt).'2 The
largest quantities of toxic metal waste streams are
produced by the mining and metallurgy and the
electroplating and metal-finishing industries. For
example, arsenic-containing flue dusts collected from
the smelting of copper, lead, zinc, and other arsenic-.
bearing ores amount to 40,000 tons (36,200 metric
tons) per year. Approximately 30,000 tons (27,200
metric tons) of chromium-bearing waste is discharged
by the metal-finishing industry annually.
-------
IDENTIFICATION AND DISCUSSION OF THE PROBLEM
TABLE 2
REPRESENTATIVE HAZARDOUS SUBSTANCES WITHIN INDUSTRIAL WASTE STREAM
Hazardous substances
Industry Chlorinated „ _ .. „ Miscellaneous
As Cd hydrocarbons* Cr Cu Cyamdes Pb H9 organicst Se Zn
Mining and metallurgy \/ V
Paint and dye V
Pesticide V
Electrical and electronic
Printing and duplicating V
Electroplating and
metal finishing \7
Chemical manufacturing
Explosives \J
Rubber and plastics
Battery \J
Pharmaceutical \/
Textile
Petroleum and coal V
Pulp and paper
Leather
* Including poly chlorinated biphenyls
'1 For example, acroiem, chloropicrin,
V V V
s/ V J
N/ V
J V V
V V
V V V
N/ V V
V
V V
V V
V
V
N/ V
V V
V V
N/
, v
V V
V
V V
V
V
v/
dimethyl sulfate, dinitrobenzene, dinitrophenol, nitroaniline,
TABLE 3
V V
V V
V N/
V
V V
V
V
V .
V V
v/
V
V
x/
V
and pentachlorophenol.
ESTIMATE OF RADIOACTIVE WASTE GENERATED IN 1970*
Waste stream source Form
Mineral extraction''' Sludge
(uranium)
Commercial nuclear Solid or liquid
electric power
Miscellaneous private Solid or liquid
sources
Government sources Solid or liquid
All known sources Sludges, solids,
or liquids
Total annual curies Tons per year
9.0 X 103 4,400,000
4.0 X 107 2,240
2.0 X iO5 11,000-22,000
Not available Not available
>4.0 X 10" >4,413,240
Metric tons per year
4,000,000
2,000
10,000-20,000
Not available
>4,012,000
Major radioactive
elements
Ra, Th, Pb, Po
U, Th, Ra, Pu, Ag,
Fe,H,Mn, Ni, Co,
Ru, Cs, Ce, Sr, Sb,
Pm, Eu, Am, Cm
Co, Sr.Pm, Cs, Pu,
Am, Cm
Pu, Am, Cm
*Source- EPA Contract No. 68-01-0762.
tUranium mill tailings from extraction of uranium ores.
Synthetic Organics. Hazardous synthetic organic
compounds include halogenated hydrocarbon pesti-
cides (such as endrin), polychlorinated biphenyls, and
phenols. An estimated 5,000 tons (4,540 metric tons)
of synthetic organic pesticide wastes were produced
in 1970.'7 DOD currently has 850 tons (770 metric
tons) of dry pesticides and 15,000 tons (13,600
metric tons) in liquid form requiring disposal. Most of
the liquid form consists of agent orange herbicide (a
mixture of 2,4-D and 2,4,5-T) banned from use in
South Vietnam.'R These stocks contain significant
quantities of a teratogenic dioxin. There are disposal
requirements caused by the increasing numbers of
waste pesticide containers as well. Over 250 million
pesticide containers of all types will be used this year
alone.19
Flammables. Flammable wastes consist mainly of
contaminated organic solvents but may include oils,
pesticides, plasticizers, complex organic sludges, and
off-specification chemicals. Highly flammable wastes
-------
DISPOSAL OF HAZARDOUS WASTES
can pose acute handling and chronic disposal hazards.
Hazards related to disposal may exceed those of
transportation and handling if sufficient waste
volumes are involved. The nationwide quantities of
flammable wastes have not been assessed as a separate
category but are included in the totals given pre-
viously.
Explosives. Explosive wastes are mainly obsolete
ordnance, manufacturing wastes from the explosives
industry, and contaminated industrial gases. The
largest amount of explosive waste is generated by
DOD. An inventory by the DOD Joint Commanders'
Panel on Disposal Ashore indicates that the military
has accumulated about 150,000 tons (136,080 metric
tons) of obsolete conventional ammunition.20 The
former practice of loading obsolete munitions on
ships and sinking them in the ocean has been
discontinued. Final disposal is being delayed until a
more suitable disposal method is available. A joint
Army, Navy, National Aeronautics and Space Admin-
istration, and Air Force group is working to resolve
this impasse. Most waste materials generated by the
commercial explosives industry consist of chemical
wastes that are not clearly separable from wastes
produced by large industrial chemical firms (e.g.,
ammonia, nitric acid, sulfuric acid, and some com-
mon organic chemicals). These wastes represent a
greater problem than military wastes because of
uncontrolled disposal practices. Open burning of
explosives, which is widely practiced, can result in the
emission of harmful nitrogen oxides and other pollut-
ants.
Radioactive Wastes
Most radioactive wastes consist of conventional
nonradioactive materials contaminated with radio-
nuclides.2 ' The concentration of the latter can range
from a few parts per billion to as high as 50 percent
of the total waste. Frequently, many radionuclides
are involved in any given waste. Radioactive wastes
are customarily categorized as low- or high-level
wastes, depending upon the concentrations of radio-
nuclides. However, the long-term hazard associated
with each waste is not necessarily proportional to the
nominal level of radioactivity, but rather to the
specific toxicity and decay rate of each radionuclide.
The most significant radionuclides, from the stand-
point of waste management, decay with half-lives of
months to hundreds of thousands of years. For the
purposes of this study, the term "high-level wastes"
refers to those wastes requiring special provisions for
dissipation of heat produced by radioactive decay;
"low-level wastes" refers to all others.
The biological hazard from radioactive wastes is
primarily due to the effects of penetrating and
ionizing radiation rather than to chemical toxicity.
On a weight basis, the hazard from certain radio-
nuclides is more acute than the most toxic chemicals
by about six orders of magnitude. The hazard from
radionuclides cannot be neutralized by chemical
reaction or by any currently practicable scheme.
Thus, the only currently practical way to "neutral-
ize" a radionuclide is to allow its decay. Storage of
wastes containing radionuclides under carefully con-
trolled conditions to assure their containment and
isolation is necessary during this decay period. The
time period necessary for decay of radionuclides to
levels acceptable for release to the environment varies
with each waste.
Radionuclides may be present in gaseous, liquid,
or solid form. Solid wastes per se are not normally
important as potential contaminants in the biosphere
until they become airborne (usually as particulates)
or waterborne (by leaching). Consequently, environ-
mental effects and existing regulatory limits are based
primarily on concentrations in air and water.
Biological Wastes
Biological wastes were divided into two categories
for this study, pathological hospital wastes and
warfare agents. Pathological wastes from hospitals are
usually less infectious than biological warfare agents.
Both types of wastes may also be toxic. For example,
toxins produced by various strains of micro-organisms
may be just as hazardous as the associated infectivity
of the organism.
Pathological Hospital Wastes. Approximately
170,000 tons (154,000 metric tons) of pathologic
wastes are generated by hospitals annually, which is
approximately 4 percent of the total 4.2 million tons
(3.7 million metric tons) of all hospital wastes
generated per year.22'23 These wastes include malig-
nant or benign tissues taken during autopsies, biop-
sies, or surgical procedures, animal carcasses and
wastes, hypodermic needles, off-specification or out-
dated drugs; microbiological wastes; and bandaging
materials.
-------
IDENTIFICATION AND DISCUSSION OF THE PROBLEM
Biological Warfare Agents. Biological warfare
agents are selected primarily because of their abilities
to penetrate outer epithelial tissues of plants or
animals and to spread rapidly. Antipersonnel agents
like Bacillus anthrax are cultured to affect a specific
animal; anticrop agents like Puccinia graminis (Lx)
(rice blast) are used to inhibit growth of specific
plants. DOD representatives have advised EPA that all
stockpiles of biological warfare agents, including
antipersonnel and anticrop agents, have been
destroyed.24 Because of the Administration's policy
of restricting production of biological warfare agents,
the- total quantity to be disposed of should be small
in the future.
ChemicaJ Warfare Agents. Production of chemical
warfare agents such as HD (mustard), GB, and VX has
been discontinued, but significant stockpiles of these
agents must be treated and disposed of in an
environmentally acceptable manner. The Department
of the Army is in the process of demilitarizing HD
(mustard) at Rocky Mountain Arsenal in Colorado
and is presently studying the feasibility of demilitariz-
ing GB and VX by means of incineration. The exact
quantity of chemical agents to be incinerated is
classified, but it has been estimated that after the
treatment process there will be approximately 70,000
tons (63,600 metric tons) of residual salts that will
require proper disposal.
FACTORS INFLUENCING THE GROWTH OF
HAZARDOUS WASTES
A number of factors will increase the quantities of
hazardous wastes generated in the future and will
affect their disposal requirements. Some of these
factors are production and consumption rates, legisla-
tive and regulatory actions, energy requirements, and
recycling incentives.
National production and consumption rates are
increasing 4 to 6 percent each year, while resource
recovery from wastes is declining. During the period
1948 to 1968, U.S. consumption of selected toxic
metals increased 43 percent.25 Since 1954, produc-
tion of synthetic organic chemicals has increased at
an average rate of 10.5 percent per year.26 Included
in the latter category are such materials as dyes,
pigments, and pesticides. Some of these products
contain heavy metals in addition to organic constit-
uents. Similar data indicating production growth can
be cited for most industries that generate hazardous
waste. There is a correlation between the amount of
production and waste generated. Therefore, it can be
concluded that hazardous waste generation rates will
generally parallel industrial production rates.
Changing product material content also has an
impact. For example, increasing polyvinyl chloride
plastics usage results in more mercury-bearing wastes
from the chlorine production industry; in the com-
puter industry, changeover from vacuum tube tech-
nology to integrated circuit board technology has
resulted in increased generation of acid etchant
wastes containing heavy metals.
The Nation's projected energy requirements are
driving utilities toward construction of nuclear-
powered facilities. As of September 1972, there were
28 nuclear power plants in operation; 52 were being
built, and 70 more were being planned. Operation of
the additional 122 nuclear power plants will
definitely increase the quantities of radioactive
wastes.27 Shortages of clean-burning high-grade coal
have initiated a trend to utilize lower grades of coal,
which contain larger amounts of arsenic and mercury;
therefore, aqueous wastes from the scrubbers and
ashes from coal-burning furnaces will contain in-
creased quantities of toxic wastes.
Enforcement of new consumer and occupational
safety legislation could result in product bans, with
attendant disposal requirements. More stringent air
and water effluent controls, new pesticide controls,
and the new restrictions on ocean dumping of wastes
will result in larger quantities of hazardous wastes in
more concentrated form requiring disposal. As air,
water, and ocean disposal options are closed off,
there will be increased pressure for improvements in
production efficiency, for recovery and recycling of
hazardous substances, and for disposal of hazardous
wastes on or under the land.
PUBLIC HEALTH AND ENVIRONMENTAL
EFFECTS
In order for an organic or inorganic hazardous
compound within a waste to affect public health and
the environment, it must be present in a certain
concentration and form. Public health and environ-
mental effects are directly correlated with the con-
centration and duration of exposure.'2'2 s This has
been better documented for acute effects resulting
-------
DISPOSAL OF HAZARDOUS WASTES
from high concentrations over a short period of time
than for chronic effects resulting from low concentra-
tions over a long period of time.29 Most of the work
to establish chronic effects has been done on lower
animals, and extrapolating the evidence directly to
man becomes difficult because of species varia-
tions.2'5
Synergistic or antagonistic interactions between
hazardous compounds and other constituents within
the waste can enhance or modify the overall effects
of the particular hazardous compound. As an exam-
ple, the effects of mercury salts with trace amounts
of copper will be considerably accentuated in a
suitable environment.
The form of a hazardous waste is also very critical
because it determines if a toxic substance is releasable
to the ambient environment. As an example, an
insoluble salt of a toxic metal bound up within a
sludge mass that is to be disposed of at a landfill does
not present the same degree of immediate threat to
public health and the environment as a soluble salt of
the same metal that is unbound going to the same
landfill. The interaction between biological systems
and hazardous wastes is unpredictable, and in many
cases the end product is more lethal than the original
waste. An example is the conversion of inorganic
mercury by anaerobic bacteria into methyl mercury.
Furthermore, persistent toxic substances can accumu-
late within tissues of mammals as do certain radio-
isotopes. Under these circumstances, substances that
are persistent in the ambient environment even
though in low concentrations will be magnified in the
living system. As a result, critical concentrations may
accumulate in tissues and cause detectable physiologi-
cal effects.
Cancers and birth defects are only a few of the
recorded physiologic effects that have been correlated
with the presence of hazardous compounds in man.
Other milder effects have also been recorded, such as
headaches, nausea, and indigestion. In the environ-
ment, the effects of hazardous wastes are manifested
by such things as fishkills, reduced shellfish produc-
tion, or improper eggshell synthesis.30
This evidence points to the fact that hazardous
wastes are detrimental to public health and the
environment. The real issue, therefore, is to docu-
ment the fact that present management practices for
treating, storing, or disposing of hazardous wastes do
not provide the necessary reassurances that man or
the environment are being adequately protected.
PRESENT TREATMENT AND DISPOSAL
TECHNOLOGY
Treatment processes for hazardous waste streams
should perform the following functions: volume
reduction where required, component separation,
detoxification, and material recovery. No single proc-
ess can perform all these functions; several different
processes linked in series are required for adequate
treatment. Residues from these processes, or all
hazardous wastes if treatment is bypassed, require
ultimate disposal.
Treatment and disposal technology is available to
process most hazardous waste streams. A range of
treatment and disposal processes was examined
during the course of this study and the general
applicability of these processes to types and forms of
hazardous wastes is indicated (Table 4). Many of
these processes have been utilized previously for
managing hazardous wastes in industry and Govern-
ment. Several processes have capabilities for resource
recovery. Selection of appropriate methods depends
on the type, form, and volume of waste, the type of
process required to achieve adequate control, and
relative economics of processes.
Several treatment processes perform more than
one function or are applicable to more than one type
or form of waste. For example, evaporation provides
both volume reduction and component separation for
inorganic liquids. Carbon sorption and filtration
provide component separation for both liquids and
gases and are applicable to a wide range of hetero-
geneous waste streams. Both carbon sorption and
evaporation are capable of large throughput rates.
Neutralization, reduction, and precipitation are effec-
tive for separation of most heavy metals.3''J 2
Certain weaknesses are inherent in some treatment
processes. For example, the five biological treatment
processes are inefficient when waste streams are
highly variable in composition and concentration or
when solutions contain more than 1 to 5 percent
salts.33 Furthermore, biological treatment processes
require larger land areas for facilities than the other
physical or chemical processes. The efficiency of
removal of hazardous liquids and gases from waste
streams by carbon sorption is strongly dependent on
pH. Similarly, the four dissolved solid removal proc-
-------
IDENTIFICATION AND DISCUSSION OF THE PROBLEM
TABLE 4
CURRENTLY AVAILABLE HAZARDOUS WASTE TREATMENT AND DISPOSAL PROCESSES*
Process
Physical treatment-
Carbon sorption
Dialysis
Electrodialysis
Evaporation
Filtration
Flocculation/settling
Reverse osmosis
Ammonia stripping
Chemical treatment
Calcination
Ion exchange
Neutralization
Oxidation
Precipitation
Reduction
Thermal treatment'
Pyrolysis
Incineration
Biological treatment.
Activated sludges
Aerated lagoons
Waste stabilization ponds
Trickling filters
Disposal/storage
Deep-well injection
Detonation
Engineered storage
Land burial
Ocean dumping
Functions
performed^
VR, Se
VR, Se
VR,Se
VR, Se
VR, Se
VR, Se
VR, Se
VR, Se
VR
VR, Se, De
De
De
VR, Se
De
VR, De
De, Di
De
De
De
De
Di
Di
St
Di
Di
Types of waste -!:
1,3,4, 5
1,2, 3,4
1,2, 3,4, 6
1,2,5
1,2,3,4,5
1,2,3,4,5
1,2,4,6
1, 2, 3.4
1,2,5
1, 2, 3,4,5
1,2,3,4
1,2,3,4
1,2, 3,4,5
1,2
3,4,6
3,5,6, 7,8
3
3
3
3
1,2,3,4, 6,7
6,8
1,2, 3,4, 5, 6, 7, 8
1,2,3,4, 5,6,7,8
1,2,3,4,7,8
Forms
of waste >
L, G
L
L
L
L, G
L,
L
L
L
L
L
L
L
L
S, L, G
S,L, G
L
L
L
L
L
S, L, G
S, L, G
S, L
S, L, G
Resource
recovery
capability
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
No
No
No
No
No
No
No
No
No
^Sources EPA Contract Nos. 68-03-0089, 68-01-0762, and 68-01-0556.
^Functions' VR, volume reduction, Se, separation; De, detoxification, Di, disposal, and St, storage.
t Waste types. 1, inorganic chemical without heavy metals; 2, inorganic chemical with heavy metals; 3, organic chemical
without heavy metals; 4, organic chemical with heavy metals, 5, radiological; 6, biological; 7, flammable; and 8, explosive.
§ Waste forms'. S, solid; L, liquid; and G, gas
esses (ion exchange, reverse osmosis, dialysis, and
electrodialysis) are all subject to operational problems
when utilized for treating heterogeneous brines.3 3
Radioactive emissions and effluents from produc-
tion or reprocessing facilities are routinely controlled
by a variety of treatment methods. High efficiency
filters are used to remove radioactive participates
from gaseous effluents; caustic scrubbers of charcoal
absorbers are used to remove radioactive gases. Liquid
effluents containing small quantities of soluble or
insoluble radioactive constituents are usually treated
with conventional water treatment techniques such as
ion exchange, settling, precipitation, filtration, and
evaporation.34
Commonly used disposal processes for hazardous
wastes include land burial, deep-well injection, and
ocean dumping. Detonation and open burning are
sometimes used for disposal of explosives. Incinera-
tion is used for disposal of some organic chemicals,
biologicals, and flammables.
All disposal processes have potential for adverse
public health and environmental effects if used
unwisely or without appropriate controls. Land dis-
posal sometimes consists of indiscriminate dumping
on the land, with attendant public health problems
from animal vectors; water pollution from surface
water runoff and leaching to groundwaters, and air
pollution from open burning, windblown particulates,
and gas venting. Sanitary landfills are much
preferable to dumps in that daily earth cover mini-
mizes vector problems and open burning and particu-
late transport. Unless specially designed, however,
-------
10
DISPOSAL OF HAZARDOUS WASTES
sanitary landfills still have potential for surface and
groundwater pollution and air pollution from gas
venting. Deep-well injection of liquid and semiliquid
wastes can pollute groundwaters unless great care is
taken in site selection and construction and operation
of such wells. EPA policy opposes deep-well injection
unless all other alternatives have been found to be less
satisfactory in terms of environmental protection and
unless extensive hydraulic and geologic studies are
made to ensure that groundwater pollution will be
minimized. Environmental problems associated with
ocean dumping have long been recognized. The
Congress recently passed legislation to control ocean
dumping of wastes (Section 3). Incineration, open
burning, and detonation all can result in air pollution
unless adequate controls are employed. The residues
from incineration, and from associated pollution
control devices, may require special care in disposal.
Selection of appropriate treatment and disposal
methods for a given waste is a complex process. It is
simplistic to assume that a treatment and disposal
process is applicable to all wastes of a given category.
For example, available treatment and disposal proc-
esses for three types of heavy metal hazardous
CONCENTRAT ED
HL-AVY METALS
HFXAVALENT
CHROMIUM
HEAVY METAL
REDUCTION AND
PRECIPITATION
HEAVY METAL SLUDGE
DISPOSAL: POLYMER
ENCAPSULATION
AND BURIAL
CADMIUM, ARSENIC,
AND Mf-PCUH V
HEAVY METAL
SULFIDE
PRECIPM A riON
HEAVY METALSLUDGE
DISPOSAL. CEMENT
ENCAPSULATION
AND BURIAL
HLAW METALS
WITH ORGANICS
AFIShNIC AND ORGANICS"
(DILUTE HYDROCARBON)
HEAVY METAL
SULFIDE
PRECIPITATION
HEAVY METALSLUDGE
DISPOSAL CEMENT
ENCAPSULATION
AND BURIAL
INCINERATION OF
DILUTE HYDROCARBON
INCINERATION OF
DILUTE HALOGENATED
HYDROCARBON
AND SCRUBBING
ACTIVATED
CARBON TREATMENT
ACTIVATED
CARBON REGENERATION
Fiyure 1, Examples of interrelationships between hazardous wastes and treatment and disposal processes. (Source' EPA
Contract No. 68-01-0556 )
-------
IDENTIFICATION AND DISCUSSION OF THE PROBLEM
11
wastes-hexavalent chromium; cadmium, arsenic, and
mercury; and arsenic and organics (dilute hydro-
carbon)-exhibit significant differences (Figure 1).
Transfer and adaptation of existing technology to
hazardous waste management may be necessary in
some cases. Some hazardous waste streams (e.g.,
those containing arsenites and arsenates of lead,
sodium, zinc, and potassium, and arsenic trioxide)
cannot be treated or disposed of adequately with
existing technology.35 Secured storage is available
until the appropriate treatment and disposal technol-
ogy is developed. Synopses of treatment and disposal
processes are given in Appendix D.
Public Use of Existing Technology
AEC and DOD presently utilize almost all the
processes identified (Table 4) for management of
hazardous wastes. High-level radioactive treatment
and storage sites operated by AEC are located at
Hanford, Washington; Savannah River, South Caro-
lina; and the National Reactor Testing Station in
Idaho. Similar DOD-operated nonradioactive hazard-
ous waste treatment, storage, and disposal sites are
located at a great number of arsenals, depots, and
ammunition plants throughout the country.
Private Use of Existing Technology
Some large manufacturers, notably in the chemical
industry, have established in-house hazardous waste
processing facilities which utilize some of the treat-
ment and disposal processes identified (Table 4).
EPA-held data on such in-house operations are sparse.
From available ocean and land disposal data, it is
estimated, however, that only a small percentage of
the hazardous wastes generated by industry receive
treatment and are disposed of at in-house facilities.
The Hazardous Waste Processing Industry
In recognition of this situation, several private
companies have built facilities to treat, dispose of,
and recycle many hazardous wastes. These companies
sell waste processing services to industries in their
areas, generally within a 500-mile (805-kilometer)
radius. However, largely because of lack of demand
for services, these regional waste processing plants
still are few in number (about 10 nationwide) and
operate at about 25 percent of available capacity.
The total processing capacity of all facilities is
approximately 2.5 million tons (2.3 million metric
TABLE 5
SUMMARY OF INFORMATION ON PRIVATELY OWNED
REGIONAL HAZARDOUS WASTE PROCESSING
PLANTS*
Item
Amount
Number of regional plants
Estimated available capacity
Estimated utilization of
available capacity
Available capacity as percent
of required nationwide
capacity
Regional distribution
Total capital investment
Resource recovery
Approximately 10
2,500,000 tons per year
(2,272,000 metric tons
per year)
25 percent
25 percent
Mostly in North Central,
Mid Atlantic, and Gulf
Coast Regions
$25 million
Limited at present mostly
to solvents and metal-
lic salts
*This table does not consider very small firms with
limited facilities (e.g., those plants that consist solely of an
incinerator).
tons) per year (Table 5). Operating at full capacity,
these private processing firms presently could handle
about 25 percent of the total nationwide nonradio-
active hazardous wastes. None of these facilities
provide a complete range of treatment and disposal
processes capable of handling all types of hazardous
wastes (Table 5).
As stated earlier, nuclear weapons production
facilities, commercial nuclear power reactors, and
private sources generate a substantial quantity of
high- and low-level radioactive wastes. High-level
wastes are controlled by AEC. Management of low-
level wastes by private companies at AEC or coopera-
tive State sites is a highly specialized business with
limited markets. As a result, there are only two
companies engaged in handling and disposing of
low-level radioactive wastes. The quantities of radio-
active wastes are expected to increase exponentially
starting around 1980, and, as a result, the number of
nuclear waste disposal companies should also
increase.
ECONOMIC INCENTIVES
The costs associated with proper hazardous waste
treatment and disposal are fixed capital intensive and
vary widely, depending on the particular treatment
process that is required. Examination of typical
-------
12
DISPOSAL OF HAZARDOUS WASTES
capital and operating costs for a number of selected
processes that are applicable to medium-size regional
industrial waste treatment and disposal facilities
illustrates that environmentally adequate technology
is expensive (Table 6). Moreover, to arrive at the
actual costs associated with proper treatment of
hazardous wastes, a combination of several treatment
processes is usually required.
The comparative economics of proper hazardous
waste management versus presently used environmen-
tally inadequate practices, such as disposal in dumps
or in the ocean, indicate that adequate treatment and
disposal of hazardous wastes cost 10 to 40 times
more than the environmentally offensive alternatives
(Figure 2). With these kinds of economic differen-
tials, and in the general absence of pressures to do
otherwise, one realizes why the more environmentally
acceptable methods are seldom utilized. Available
technology cannot compete economically with the
cheaper disposal alternatives. Clearly, there are sub-
stantial economic incentives for industry not to use
adequate hazardous waste treatment and disposal
methods.
Should a generator elect to process his hazardous
wastes in an environmentally acceptable manner, a
basic decision must be made whether the particular
waste stream should be processed on site or off site at
some regional treatment facility, such as existing
commercial waste processing plants. The cost analysis
of this problem, as it applies to a number of
commonly occurring industrial waste streams, was
conducted by means of a mathematical model that
produced "economic decision maps."36 Typical
examples are attached in Appendix E. An analysis of
the decision maps indicates that cost factors generally
favor off-site treatment and disposal of industrial
hazardous wastes with the exception of dilute aque-
ous toxic metal streams. Other factors, such as the
impact of pending water effluent standards and
transportation problems, may alter this judgment.
SUMMARY
EPA's findings relative to the current handling of
hazardous wastes can be summed up as follows:
(1) Current treatment and disposal practices are
inadequate and cause unnecessary hazards to all life
forms.
(2) Techniques for safe and environmentally
sound treatment and disposal of most hazardous
wastes have been developed. Adaptation and transfer
of existing technology and development of new
methods are required in some cases. It is possible to
retain hazardous wastes for which treatment and
disposal methods are unavailable in long-term storage
until their chemical conversion to harmless com-
pounds or their reuse in industrial practice becomes
feasible.
TABLE 6
COSTS OF REPRESENTATIVE HAZARDOUS WASTE TREATMENT PROCESSES*^
Process
Chemical oxidation of cyanide wastes
Chemical reduction of chromium wastes
Neutralization/precipitation
Liquid-solid separation
Carbon sorption
Evaporation
Incineration
Capacity
1,000 gal/day 1,000
25
42
120
120
120
120
1l?4
liters/day
94.8
159
452
452
452
452
**67
Capital costst
($1,000)
400
340
3,000
9,000
910
510
4,900
Operating
$/l,OOOgal
68
29
50
40
7
10
tt95
costs §
$/ 1,000 liters
18
7.65
13.20
10.60
1.85
2.64
1-1 105
*Source; EPA Contract No. 68-01-0762.
'''Data correspond to a typical medium-size treatment and disposal facility capable of processing approximately 150,000 tons
(136,000 metric tons) per year or 600 tons (545 metric tons) per day.
•1-Capital costs include land, buildings, and complete processing and auxiliary facilities.
^Operating costs include neutralization chemicals, labor, utilities, maintenance, amortization charges (7 percent interest),
insurance, taxes, and administrative expenses.
^Tons per day.
**Metric tons per day.
ttDollars per ton.
t1 Dollars per metric ton.
-------
IDENTIFICATION AND DISCUSSION OF THE PROBLEM
13
" 400 (106.00)
o
o
o
•-" 300 (79 40)
S 200 (52.80)
o
o
o
- 100 (2640)
o
Cfl
I-
" 50 (13.20)
O
z
O
o
cc
15
5
(3.96)^-
(1 32 )-
A = ENVIRONMENTALLY ADEQUATE TREATMENT AND DISPOSAL
B = LAND DISPOSAL
C = OCEAN DISPOSAL
25
(94.6)
120
(454)
200
(758)
1,000
(3,7851
WASTE VOLUME [ 1,000 gal/day (1,000 liters/day)!
Figure 2. Cost comparison of proper versus improper hazardous waste management practices for aqueous wastes. Data
include capital writeoff but not transportation costs from the generator to the nearest treatment or disposal facility. Note the
economies of scale attainable by using large waste processing facilities. (Source: EPA Contract Nos. 68-01-0762 and 68-03-0089;
based on cost data from typical treatment and disposal facilities capable of handling aqueous toxic wastes.)
(3) There are substantial economic incentives for
industry not to use environmentally adequate treat-
ment and disposal methods. Such methods are sub-
stantially more expensive than current inadequate
practices, and in a climate of permissive legislation or
total absence of legislation, competitive economic
forces result in least-cost disposal regardless of the
environmental consequences.
(4) A small industry has emerged to treat and
dispose of hazardous and other industrial wastes. This
industry is not currently operating at capacity be-
cause its services are being utilized only by a few
clients who are concerned about the environment,
have no cheaper disposal alternatives, or sometimes
find themselves forced to use such services because of
environmental regulations. This industry, however,
has the capability to expand to meet demands
engendered by future Federal or State actions.
It is evident that a need exists for bringing about
environmentally acceptable and safe treatment and
disposal of hazardous wastes. A discussion of the
need for a regulatory program to achieve this goal
follows in Section 3.
-------
-------
Section 3
THE CASE FOR HAZARDOUS WASTE REGULATIONS
The potential for public health and environmental
damages from mismanagement of hazardous wastes
and the lack of economic incentives for proper
management has been described in Section 2. There is
a strong precedent for Federal regulation when health
damage is at issue. Regulation is used because the
other conceptual alternative, massive economic incen-
tives, does not ensure compliance. Some forms of
regulation, however, may embody certain types of
economic incentives. Federal and State statutes have
attempted to regulate and control various parts of the
problem, but there has never been an attempt to
regulate hazardous waste management in a compre-
hensive manner.
The following discusses legislative precedents that
relate to hazardous wastes and illustrates a legislative
gap in the regulation of land disposal of hazardous
wastes.
EXISTING AUTHORITIES FOR HAZARDOUS
WASTE MANAGEMENT
A large body of Federal and State law exists today
which exerts a significant but peripheral impact on
the land disposal of hazardous wastes. The following
discussion reviews existing laws and assesses their
impact on the treatment, storage, transportation,
handling, and disposal of hazardous wastes.
Federal Control Statutes
Thirteen Federal statutes have varying degrees of
direct impact on the management of hazardous
wastes. Four additional Federal statutes are either
indirectly or potentially applicable to hazardous
wastes. The Clean Air Act, as amended, and the new
Federal Water Pollution Control Act (FWPCA) are
discussed in some detail later in this section. The
other statutes and their impact on the treatment,
storage, transportation, and handling of hazardous
wastes are summarized in the following.
Section 212 of the Resource Recovery Act of
J 970 directs the Administrator of EPA to study the
feasibility of a system of national disposal sites for
hazardous wastes.37 The act authorizes no regulatory
activities, however.
The Atomic Energy Act of 1954, as amended,
authorizes AEC to manage radioactive wastes gen-
erated in fission reactions by both AEC and private
industry.38 High-level radioactive wastes from
weapons and reactor programs are controlled directly
by AEC at its facilities; commercially generated
low-level radioactive wastes are generally disposed of
at facilities licensed and controlled by the States.
Naturally occurring materials, such as uranium mill
tailings and radium, and radioisotopes produced by
cyclotrons are not subject to regulation under the act.
There is room for improvement at the radioactive
waste storage and disposal facilities, but compared
with the management of other hazardous wastes,
high-level radioactive waste management is well regu-
lated.
The Department of Transportation (DOT) is
responsible for administering five statutes which
affect the transport of hazardous wastes. The oldest
of these, the Transportation of Explosives Aut, pro-
hibits the knowing unregulated transport of explo-
sives, radioactive materials, etiologic (disease-causing)
agents, and other dangerous aiticles in interstate
commerce unless the public interest requires expe-
dited movement or such transport involves ''no
appreciable danger to persons or property."3' Supple-
menting this law is the Hazardous Materials Trans-
portation Act of 1970, a nomegulatory statute which
authorizes the Socretaiy of DOT 10 evaluate hazards
associated with hazardous materials transport, estab-
lish a central accident reporting system, and recom-
mend improved hazardous material transport con-
trols.40 The Safety Regulation of Civil Aeronautics
15
-------
16
DISPOSAL OF HAZARDOUS WASTES
Act authorizes the Federal Aviation Administration
to establish air transportation standards "necessary to
provide adequately for national security and safety in
air commerce."41 The Hazardous Cargo Act places
regulatory controls on the water transport of explo-
sives or dangerous substances, authorizing the U.S.
Coast Guard to publish regulations on packing,
marking, labeling, containerization, and certification
of such substances.42 The Federal Hazardous Sub-
stances Labeling Act authorizes the Secretary of DOT
to identify hazardous substances and prohibits the
transport of such substances if their containers have
been misbranded or the labels have been removed.43
The act authorizes the seizure of misbranded hazard-
ous substances and requires the courts to direct the
ultimate disposition of such seized substances.
The Federal Environmental Pesticide Control Act
of 1972 requires the Administrator of EPA to
establish procedures and regulations for the disposal
or storage of packages, containers, and excess
amounts of pesticides.44 EPA is also required to
"accept at convenient locations for safe disposal"
those pesticides whose registration is suspended to
prevent an imminent hazard and later canceled if the
pesticide owner so requests.44
The Marine Protection, Research, and Sanctuaries
Act of 1972 prohibits the transport from the United
States for the purpose of ocean dumping any radio-
logical, chemical, or biological warfare agents, high-
level radioactive wastes, or (except as authorized by
Federal permit) any other material.4'1 In granting
permits for ocean dumping, the EPA Administrator
must consider "appropriate locations and methods of
disposal or recycling, including land-based alterna-
tives, and the probable impact of [such use] upon
considerations affecting the public interest."46
The Clean Air Act and the Federal Water Pollution
Control Act, examined in detail later in this section,
provide extensive control authority over the incinera-
tion and water disposal of certain hazardous
wastes.47'48
The Poison Prevention Packaging Act authorizes
the Secretary of Health, Education, and Welfare to
establish special packaging standards for hazardous
household substances whenever it can be shown that
serious personal injury or illness to children can result
from handling, using, or ingesting such substances.49
Hazardous household substances already identified in
regulations include oven cleaners, cigarette and char-
coal lighter fluids, liquids containing turpentine and
methyl alcohol, and economic poisons (pesticides).
The Food, Drug and Cosmetic Act prohibits the
adulteration and misbranding of certain consumer
items and requires the disposal by destruction or sale
of any items seized under the act.s °
The first of the Federal statutes that has a general,
nonregulatory impact on the management of hazard-
ous wastes is the National Environmental Policy Act
of 1969 (NEPA).5' Section 101(b) of NEPA requires
the Federal Government to "use all practicable
means" to attain the widest range of beneficial uses
without degrading the environment or risking health
or safety. In order to ensure that the environmental
policies expressed in Section 101 are effectively
carried out, Section 102(2)(C) requires all agencies of
the Federal Government to prepare detailed environ-
mental impact statements for all "major Federal
actions significantly affecting the quality of the
human environment." All Federal hazardous waste
management activities thus clearly fall within NEPA's
ambit.
The Armed Forces Appropriation Authorization
Acts of 1969 and 1970 prohibit the use of Federal
funds for the transportation, open-air testing, or
disposal of any lethal chemical or biological warfare
agent in the United States except under certain
conditions requiring prior determination of the effect
on national security, hazards to public health and
safety, and practicability of detoxification prior to
disposal.52'53
The CoastaJ Zone Management Act of 1972, in
declaring it a national policy to preserve and protect
the resources of the Nation's coastal zone, recognizes
waste disposal as a "competing demand" on coastal
zone lands which has caused "serious environmental
losses."54 Because applicants for Federal coastal zone
managment grants must define "permissible land and
water uses within the coastal zone," an applicant's
failure to regulate hazardous waste disposal within
such area so that it qualifies as a "permissible use"
can serve as a basis for denying program funds under
the act.
The Occupational Safety and Health Act of 1970
(OSHA) authorizes the Secretary of Labor to set
-------
THE CASE FOR HAZARDOUS WASTE REGULATIONS
17
mandatory standards to protect the occupational
safety and health of all employers and employees of
businesses engaged in interstate commerce.55 Section
6(b)(5) deals specifically with toxic materials and
other harmful agents, requiring the Secretary to "set
the standard which most adequately assures. . . that
no employee will suffer material impairment of
health or financial capacity" from regular exposure to
such hazards. Employees of hazardous waste genera-
tors and treatment and disposal facilities engaged in
interstate commerce thus are clearly entitled to the
act's protection. It should be noted that standards
issued under the act can directly impact some phases
of hazardous waste management. For example, the
OSHA-enforced asbestos regulation requires that cer-
tain wastes be packaged for disposal.
State Control Statutes
At least 25 jurisdictions have enacted legislation or
published regulations which control hazardous waste
management activities to some degree. The most
effective of these regulatory controls are currently
placed on low-level radioactive wastes, AEC having
contracted with a growing number of States for
low-level radioactive waste disposal. Nonradioactive
hazardous wastes, however, are essentially unregu-
lated in practice, for none of the 25 jurisdictions has
fully implemented its control legislation. The major
reason for this failure is the negative approach-
broadly worded blanket prohibitions-utilized by
virtually all of these States.
Legislative strategies which rely on blanket prohi-
bitions rather than comprehensive management con-
trols are difficult or impossible to administer in any
meaningful, systematic fashion. In addition, many of
these States enact control statutes without providing
for acceptable treatment or disposal facilities. A
recent survey of 16 of the 25 "control" States
reveals, for example, that less than half of them have
treatment and disposal facilities located within their
boundaries (Table 7).5 6 By failing to specify accept-
able alternatives to prohibited activities, such States
encourage hazardous waste generators to ignore the
law altogether or to select and employ divergent
disposal alternatives unknown to the State control
authorities that may be more environmentally harm-
ful than the prohibited activity.
Summary
With the exception of radioactive waste disposal,
which appears to be the subject of adequate Federal
and State regulation, land-based hazardous waste
treatment, storage, and disposal activities are essen-
tially unregulated by Federal and State laws. Because
this legislative gap allows uncontrolled use of the land
for hazardous waste disposal, there has been little
incentive for the use of proper hazardous waste
treatment and disposal technology to date. Until
nationwide controls are established, the pressure on
the land as a receptor for hazardous wastes can be
expected to increase as the major hazardous waste
disposal controls of the Clean Air Act, the FWPCA,
and the new Federal ocean dumping statute are
tightened. The latter statute's mandate to the EPA
Administrator to consider land-based disposal alterna-
tives when granting ocean dumping permits seems
certain to provide opponents of the practice of
dumping toxic wastes into the ocean with a new and
powerful legal tool. Depending on the courts' inter-
pretation of this statute, the Marine Protection,
Research, and Sanctuaries Act of 1972 could add
significantly to the pressure on land as the last
disposal medium for hazardous wastes.
PRECEDENTS FOR HAZARDOUS WASTE
REGULATION
Both the Clean Air Act and the FWPCA include
provisions that address the problem of hazardous
waste management directly.47'4* The former statute
authorizes the control of hazardous air pollutants,
and the latter controls the discharge of hazardous
pollutants into the Nation's waters.
The Clean Air Act best exemplifies a control
strategy designed to protect the public health and
welfare by placing the burden of standards compli-
ance on the air polluter. As with most environmental
control statutes, the costs of compliance are internal-
ized by the polluter and ultimately passed on to the
consumer, indirectly in the form of tax benefits to
the polluting industries, or directly in the form of
higher prices for goods and services.57 In the past,
Clean Air Act standards have been based almost
exclusively on health effects. As a result of adverse
court decisions on ambient air quality standards,
however, EPA has expanded its efforts to consider, in
-------
18
DISPOSAL OF HAZARDOUS WASTES
TABLE 7
SUMMARY OF STATE LEGISLATION SURVEY*
Solid waste
State
Alabama
California
Colorado
Illinois
Kansas
Maine
Michigan
Nevada
New Jersey
New York
Oregon
South Carolina
Texas
Vermont
Virginia
Washington
State
Alabama
California
Colorado
Illinois
Kansas
Maine
Michigan
Nevada
New Jersey
New York
Oregon
South Carolina
Texas
Vermont
Virginia
Washington
Disposal
regulations
Yes
Yes
Yes
No
Yes
No
Yes
No
Yes
Yes
Yes
Yes
Yes
No
Yes
Yes
Licensing of
disposal sites Disposal
Yes
Yes
Yes
Yes
Yes
No
Yes
No
Yes
Yes
Yes
Yes
Yes
No
No
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Explosives
Radioactive material
Regulations on
Transportation Processing
Yes
Yes
No
Yes
Yes
Yes
Yes
Yes
Yes
Yes
No
No
Yes
Yes
Yes
No
Yes
Yes
No
Yes
Yes
Yes
Yes
Yes
Yes
Yes
No
No
Yes
Yes
Yes
No
Storage
Yes
Yes
No
Yes
Yes
Yes
Yes
Yes
Yes
Yes
No
Yes
Yes
Yes
Yes
No
Transportation
Disposal
Yes
Yes
No
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
No
No
Yes
Yes
Yes
Industr
Pesticides
Regulations on.
Transportation
Yes
Yes
No
Yes
Yes
No
Yes
No
No
No
Yes
No
-
No
No
No
ial safety
Processing Storage
Yes
Yes
No
Yes
Yes
No
Yes
No
No
No
No
No
Yes
No
No
No
Yes
Yes
No
Yes
Yes
No
Yes
Yes
No
No
Yes
No
Yes
No
No
No
Presence of existing
regulations for
Disposal
_
No
No
-
Yes
Yes
Yes
Yes
Yes
Yes
Yes
No
_
Yes
Yes
Yes
Regulations on
Transportation Processing Storage
Yes
No
Yes
Yes
Yes
Yes
No
Yes
Yes
Yes
Yes
-
Yes
Yes
Yes
._
No
No
Yes
-
-
No
Yes
Yes
No
No
-
Yes
Yes
No
_
Yes
No
-
Yes
-
-
Yes
Yes
Yes
Yes
No
_
Yes
Yes
Yes
DOT
regulations
Yes
Yes
Yes
Yes
Yes
Yes
No
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Other ^
_
Yes
No
Yes
Yes
Yes
No
-
-
No
Yes
Yes
-
No
handling
hazardous
materials
Yes
Yes
No
-
Yes
Yes
No
No
Yes
No
-
_
No
No
No
facilities
Radioactive
Yes
-
No
Yes
Yes
No
No
No
Yes
Yes
No
Yes
Yes
No
No
Yes
Hazardousi
No
Yes
No
No
-
No
Yes
No
Yes
Yes
No
No
Yes
No
No
Yes
*Source EPA Contract No 68-01-0762
11ncludes hauling permits, vehicle registrations, material registrations, bills of lading, placard attachment, and vehicle standards
•£Includes pesticides, toxic substances, and other chemicals.
addition to health and welfare factors, (1) beneficial
and adverse environmental effects; (2) social,
economic, and other pertinent factors; (3) the
rationale for selecting the standard from the available
options.58'60
The FWPCA Amendments of 1972 generally
exemplify a control strategy based on factors in
addition to human health and welfare. Typical of the
FWPCA's new regulatory provisions are those keyed
to "best practicable" control technology and "best
available technology economically achievable," deter-
minations which are to be made by EPA from studies
of the age, size, and unit processes of the point
sources involved and the cost of applying effluent
controls.
The Clean Air Act
Section 112 of the Clean Air Act authorizes the
Administrator of EPA to set standards for hazardous
air pollutants at any level "which in his judgment
provides an ample margin of safety to protect the
public health."6 ' Hazardous air pollutants are defined
as those which "may cause, or contribute to an
increase in mortality or an increase in serious irrevers-
ible or incapacitating reversible, illness" [Section
112(a}(l)j. Asbestos, beryllium, and mercury are
three hazardous pollutants for which emission limits
under Section 112 have been promulgated.
The Federal Water Pollution Control Act
The FWPCA contains a number of provisions with
direct impact on hazardous pollutant-bearing wastes.
-------
THE CASE FOR HAZARDOUS WASTE REGULATIONS
19
Section 502(13) defines "toxic pollutant" as "those
pollutants . . . which . . . after discharge and upon
exposure, ingestion, inhalation or assimilation into
any organism . . . will cause death, disease, behavioral
abnormalities, cancer, genetic mutations, physiologi-
cal malfunctions... or physical deformations on
such organisms or their offspring." Section 115
directs EPA to locate and contract for "the removal
and appropriate disposal of [in-place toxic pollutant |
materials from critical port and harbor areas." The
potential for increased pressure for land disposal of
such toxic pollutants is evident.
Title III of the FWPCA contains four provisions
authorizing control over toxic pollutants discharged
into water from point sources. The importance of the
FWPCA's distinction between point and nonpoint
sources cannot be overemphasized from a hazardous
waste management viewpoint, for discharges from
point sources only are subject to the act's regulatory
controls.* Because the act defines "point source" as
"any discernible, confined and discrete conveyance,"
and offers as examples such things as pipes, ditches,
and tunnels, Congress seems not to have intended
that land disposal facilities are to be included within
the point source definition.62 In fact, the opposite
appears to be true, for Section 304(e) of the act
requires EPA to publish nonregulatory "processes,
procedures, and methods to control pollution result-
ing from . . . the disposal of pollutants in wells or in
subsurface excavations" \ emphasis supplied | .6 3
Since the types of pollutant discharges normally
associated with improperly managed hazardous waste
disposal facilities are runoff into navigable waters and
migration into groundwater supplies, it seems safe to
conclude that, unless a disposal facility discharges
toxic pollutants into a waterway through a "discerni-
ble, discrete conveyance," such as an outfall pipe, it
will be exempt from the act's proscriptions.
Hazardous waste treatment facilities, however,
should not escape the act's reach. Any toxic wastes
produced by such facilities and not treated on site
must be stored and/or eventually transported in some
manner, and any container or confined means of
conveyance for such waste, by definition in Section
502(13) of the act, qualifies as a potential point
source of water pollution discharge.
The first of Title Ill's proscriptions against toxic
pollutant discharges may be found in Section 301(f),
which prohibits the "discharge of any radiological,
chemical, or biological warfare agent, or high level
radioactive waste into the navigable waters." The
other statutory authorities which impact on the
disposal of these wastes were discussed previously.
Section 306 is the second reference to hazardous
wastes. It requires EPA to publish national standards
of performance for new point source categories
reflecting "the greatest degree of effluent reduction
achievable . . . , including where practicable, a stand-
ard permitting no discharge of pollutants."64 The act
singles out such new source categories as the organic
and inorganic chemicals industries, well-known
generators of toxic wastes. These standards, which
must take into account the cost of standards'
achievement and "any non-water quality environ-
mental impact and energy requirements,"* must be
published not later than January 1974. Hazardous
waste generators and treatment facilities which other-
wise qualify as "new" clearly are comprehended in
Section 306(a)(3), which defines new sources as "any
building, structure, facility, or installation from
which there is or may be the discharge of pollutants."
This adds to the general qualification of such facilities
as point sources.
The third FWPCA provision affecting toxic pollut-
ants is Section 307, which requires EPA to identify
and publish effluent standards for a list of toxic
pollutants or combinations of such pollutants. Stand-
ards are to be set "at that level which the Administra-
tor determines provides an ample margin of safety,"
and are to take effect not later than 1 year after
promulgation.65 Even though Congress' standard-
setting process mandate to EPA under this section
*Section 301 (a) established FWPCA's broad prohibi-
tions against the "discharge of any pollutant " Section
502(12) defines "discharge of pollutants" as "any addition of
any pollutant to navigable waters from any point source"
| emphasis supplied |
*Section 306(b)(l)(B). The FWPCA's • legislative
history, however, makes it clear that individual new sources,
rather than EPA, will determine which technologies will be
used to achieve Section 306(b)'s performance standards.
Conference Report No. 92-1465, FWPCA Amendments of
1972, 92d Congress, 2d Sess. (Sept. 28, 1972, p.128.)
-------
20
DISPOSAL OF HAZARDOUS WASTES
was limited to consideration of toxic!
-------
THE CASE FOR HAZARDOUS WASTE REGULATIONS
21
which incorporates treatment in order to lessen the
demand on land disposal alternatives. All persons who
treat the same hazardous wastes, either on site
(generators) or off site (contract service organiza-
tions), should be subject to the same treatment
standards. Processes for recovery of recyclable con-
stituents from hazardous wastes should be controlled
adequately by treatment regulations, for the tech-
nologies employed are often the same.
Other hazardous waste management activities that
should be subjected to improved controls are hazard-
ous waste transport and handling. As indicated
earlier, DOT administers a number of Federal statutes
designed to control the transportation of hazardous
materials in interstate commerce. These statutes
should be amended by DOT where necessary to
ensure that hazardous wastes are properly marked,
containerized, and transported (to authorized dis-
posal sites). The packaging and labeling provisions of
all other Federal statutes that have a potential impact
on hazardous wastes should be reviewed by EPA and
amended where necessary to ensure their applicability
to such wastes.
It should be noted that control of toxic materials
before they become toxic wastes could greatly reduce
the size of the overall hazardous waste management
problem. The proposed Toxic Substances Control
Act, now pending before Congress, would provide for
regulatory controls over toxic substances before they
become wastes. The proposed legislation authorizes
testing of chemical substances to determine their
effects on health or the environment and restrictions
on use or distribution of such chemicals when
warranted. Such restrictions may include labeling of
toxic substances as to appropriate use, distribution,
handling, or disposal, and limitations on particular
uses, including a total ban. This "front-end" approach
to toxic substances problems should dovetail neatly
with a hazardous waste regulatory program.
Types of Hazardous Waste Standards
The foundation of any regulatory program, of
course, is the body of standards the program estab-
lishes and enforces. The Clean Air Act and FWPCA
regulatory programs progressed from ambient air and
water quality standards to specific pollutant emission
and discharge standards as practical experience with
each statute's enforcement revealed the necessity for
such an evolution.6 !
Because of the nature of the discharges associated
with improperly managed hazardous waste, two types
of standards are likely to be necessary in order to
satisfactorily regulate hazardous waste treatment and
disposal: (1) The "performance" standard would set
restrictions on the quantity and quality of waste
discharged from the treatment process and on the
performance of the disposal site (e.g., the amount and
quality of leachate allowed); (2) the "process"
standard would specify treatment procedures or
process conditions to be followed (e.g., incineration
of certain wastes) and minimum disposal site design
and operating conditions (e.g., hydraulic connections
are not allowed).
The performance standards, which correspond
directly to the emission and discharge standards of
the Clean Air Act and the FWPCA, would be designed
to prevent hazardous pollutant discharges from treat-
ment and disposal facilities from reaching air and
surface waters in excess of acceptable air and water
limits. A major advantage of this type of standard is
the ability to use health and environmental effects
data and criteria already developed by EPA's Office
of Air and Water Programs and Office of Research
and Development.
Process standards would be designed to ensure that
certain treatment technologies and minimum design
and operating conditions are employed. These stand-
ards assume double importance because of the uncer-
tainty surrounding the FWPCA's standard-setting
authority regarding discharges into ambient ground-
waters,* and the act's clear lack of authority to
regulate diffuse discharges from nonpoint sources
such as land disposal sites. Process (design and
operating) standards, therefore, which are intended to
establish controls at the hazardous waste sources,
would be an important part of any regulatory
program.
Strategies for Hazardous Waste Regulation
Hazardous wastes can be regulated by three
distinct control strategies: (1) Federal only, (2) State
*Although the broad definition given to "navigable
waters" in Section 502(7) of the FWPCA arguably includes
groundwaters, the restriction of the act's regulatory provi-
sions to discharges of pollutants from point sources virtually
eliminates the most common source of groundwater pollu-
tion; i.e., runoff or leachate from nonpoint sources. (See
earlier discussion of point sources.)
-------
22
DISPO'' \L OF HAZARDOUS WASTES
only, (3) Federal/State partnership. Each of these
alternatives is examined.
Federal Only. The Federal-only type of control
strategy requires the exclusive jurisdiction of the
Federal Government (Federal preemption) over all
management activities for hazardous waste. The most
obvious advantages include national uniformity of
standards, elimination of State pollution havens for
industries controlling a significant portion of such a
State's economy, and uniform administration and
enforcement. The major disadvantages of this control
strategy are the difficulty in proving conclusively that
the hazards of human health and the environment
justify total Federal involvement, the prohibitive
costs and administrative burdens involved in main-
taining a nationwide Federal monitoring and enforce-
ment program, and the total disincentive for State
involvement in what is essentially a State problem.
The only comparable Federal program is that involv-
ing the exclusive disposal of high-level radioactive
wastes by AEC.
State Only. Under the State-only control strat-
egy, the Federal Government would establish "recom-
mended guidelines" for hazardous waste treatment
and disposal which the States could adopt as a
minimum, modify in either direction (more or less
stringent) in response to local needs and pressure
groups, or ignore altogether. These Federal guidelines
could be used to recommend what would otherwise
be process and performance standards under a
Federal regulatory program, as well as the minimum
efforts the Federal Government believes are necessary
to administer and enforce an effective State control
program. States could finance activities themselves;
alternatively, the Federal Government could offer
technical and financial support to assist States in
program development and enforcement. The major
advantage of this approach is in its low level of
Federal involvement and correspondingly low Federal
budget requirements. Another advantage includes
enhanced ability to tailor solutions to particular
problems that may be essentially local in character.
The disadvantages of the State-only approach to
hazardous waste control include its total dependence
on the States for the adoption and enforcement of
voluntary guidelines, the nonavailability of Federal
backup enforcement authority, the potential for
extreme nonuniformity between the individual States
adopting control programs, and the much greater
period of time needed to enact and fully implement
such a control system nationwide.
Federal/State Partnership. The Federal/State
partnership is the control strategy that had been
adopted by the Nation's major environmental pollu-
tion control statutes. The Federal Government would
establish minimum Federal hazardous waste treat-
ment and disposal standards; all States would be
required to adopt these as minimum State standards
within a specified time period. The States would bear
the responsibility for establishing and administering
EPA-approved State control programs. Functions
could include operating a statewide hazardous waste
facility permit program, maintaining an inspection
and monitoring force, enforcing statutory sanctions
against violators, and filing program progress reports
with EPA. As in the Federal air and water pollution
control programs, States with approved implementa-
tion programs would be eligible for Federal financial
assistance. For those States that fail to submit
approved programs, or that do not enforce the
Federal/State standards, backup Federal enforcement
powers could be exercised to ensure uniform compli-
ance or Federal program grant funds could be
withheld. Provision could also be made for a
federally administered control and enforcement pro-
gram for certain hazardous wastes determined to pose
extremely severe hazards, an approach already
utilized by AEC for high-level radioactive wastes. The
major advantage of this control strategy stems from
the well-established legislative precedents discussed
earlier; land pollution control regulations employing
this strategy would be capable of being fully inte-
grated with existing controls over air and water
pollution. Other advantages include utilizing the
Federal Government's superior resources to set stand-
ards and design programs, while retaining the concept
of State responsibility for what are traditionally
recognized as State problems; minimal Federal
involvement once the States' implementation pro-
grams are fully underway; uniform minimum national
hazardous waste standards, with States retaining the
power to set more stringent standards if local
conditions so dictate, and reasonable assurance that
the standards will be enforced ultimately by some-
-------
THE CASE FOR HAZARDOUS WASTE REGULATIONS
23
one. The disadvantages of the combined Federal/
State hazardous waste control strategy involve its
potential for delay in final implementation, since
States can be expected to demonstrate varying
degrees of readiness and interest in gearing up State
machinery to run their respective control programs.
The major drawback to this approach, however,
involves its potential for large expenditures of Federal
manpower and funds should the States choose to sit
back and "let the Feds do it"; even worse is the
possibility that Federal standards for hazardous waste
control will be completely unenforced in laggard
States simply because of the lack of adequate funds
to exercise the reserve powers. This problem seems
capable of resolution, however, if adequate incentives
for State action are made available (Federal grants or
technical assistance) and if significant disincentives
are applied (such as withholding air and water
program grant funds or characterizing the State as
"irresponsible").
SUMMARY
The earlier parts of this section describe the gap in
Federal and State hazardous waste management
legislation, a gap which if not filled soon by Congress'
adoption of a comprehensive hazardous waste control
strategy could well result in irreparable damage to the
health and environment of the Nation's citizens. The
most viable hazardous waste control strategy would
consist of a Federal/State regulatory partnership in
which the Federal Government would bear the
responsibility for setting process and performance
standards applicable to all hazardous waste treatment
and disposal activities while qualified State govern-
ments would be responsible for administering
federally approved control programs and enforcing
the Federal standards.
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Section 4
ISSUES OF IMPLEMENTATION
The previous section spells out the need for a
regulatory program. A hazardous waste regulatory
program does not directly create an NDS system as
envisioned in Section 212 of the Resource Recovery
Act of 1970. However, such a system would be
ineffective unless its use is mandated through
regulations. Even with total governmental subsidy of
its construction and operation, such a system would
not be assured of receiving all hazardous wastes.
Therefore, a regulatory program is needed in any
case.
EPA believes that private industry will respond to
a regulatory program, but there are a number of
questions relating to that response. Furthermore,
several options are available to the Government to
modify a purely private sector system to circumvent
these questions if need be.
In this section, estimates are developed of a
hazardous waste management system required to
implement a hazardous waste regulatory program, the
cost of such a system, and possible variations of the
system. Issues related to cost distribution, private
sector response, and the role of Government are
discussed thereafter.
HAZARDOUS WASTE MANAGEMENT SYSTEM
A hazardous waste management program should
result in creation of a system with certain charac-
teristics: adequate treatment and disposal capacity
nationwide, lowest cost to society consistent with
public health and environmental protection, equitable
and efficient distribution of cost to those responsible
for waste generation, and conservation of natural
resources achieved by recovery and recycling of
wastes instead of their destruction.
This system should combine on-site (point of
generation) treatment of some wastes, off-site (cen-
tral facility) treatment for hazard elimination and
recovery, and secure land disposal of residues that
remain hazardous after treatment.
Estimates of total required treatment and disposal
capacity, and the mix of on-site and off-site capacity,
are keyed to hazardous waste source quantities,
types, and geographical distribution; the degree of
regulation and enforcement, and the timing of regula-
tory and enforcement implementation. The hazard-
ous waste management scenario developed represents,
in EPA's judgment, a system with the aforementioned
characteristics. It is based on the best available source
data and technology assessments, discussions with
major waste generators and disposal firms, and
consideration of the following criteria: earth sciences
(geology, hydrology, soils, and climatology), trans-
portation economics and risk, ecology, human en-
vironment, demography, resource utilization, and
public acceptance.6 '7 '9'' ° The scenario assumes com-
plete regulation, treatment, and disposal of all non-
radioactive hazardous wastes (as defined in Appendix
B) and anticipates issuance of regulations and vigorous
enforcement of them at the earliest practicable time
period.
The scenario that follows and the cost estimates
derived from the scenario should be viewed with
caution. Given any reasonable degree of dependence
on private market choices on the part of waste
generators and waste treatment and disposal firms,
the actual implementation of a hazardous waste
management program in the United States is not
likely to follow predictable, orderly lines. Numerous
interactive factors are likely to influence the shape
and the cost of the system as it evolves-including
such factors as the impact of air and water effluent
regulations on waste stream volume and composition,
the impact of uneven response to regulatory pressures
from region to region, changes in technology, and
25
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26
DISPOSAL OF HAZARDOUS WASTES
shifting locational patterns. What follows, therefore,
should be considered as one of many possible
permutations of the system. Nonetheless, the scenario
does represent EPA's current best judgment of a
reasonable, environmentally adequate hazardous
waste management system.
As noted previously, approximately 10 million
tons (9 million metric tons) of nonradioactive hazard-
ous wastes are generated per year. Of these, about 60
percent by weight are organics and 40 percent are
inorganics; about 90 percent of these wastes are
aqueous in form.
Economic analyses indicate that on-site treatment
is generally justified only for dilute aqueous toxic
metal wastes and only where the generation rate is
high (Appendix E). From analyses of source data, it is
estimated that about 15 percent of the total wastes
(1.5 million tons or 1.36 million metric tons) are in
the dilute aqueous toxic metal category and would be
pretreated by generators on site. Since on-site facil-
ities are anticipated to be small in scale compared to
off-site facilities, about 50 on-site facilities each
capable of handling approximately 30,000 tons
(27,000 metric tons) per year would be economically
justified. About one-third (0.5 million tons or 0.45
million metric tons) of pretreated wastes would
require further processing at off-site facilities.
In this postulated scenario, therefore, most of the
wastes (8.5 million tons or 7.7 million metric tons
plus pretreatment residues) would be transported to
off-site facilities for treatment and disposal. The size
and location of treatment plants is likely to corre-
spond to patterns of waste generation: Larger facil-
ities would be located in major industrial regions,
smaller facilities elsewhere. Background studies have
identified the location of industrial waste production
centers and the designs and unit costs of small-,
medium-, and large-size processing facilities
(Appendix F).
A reasonable prediction is that five large facilities,
each capable of handling approximately 1.3 million
tons (1.2 million metric tons) per year, would be
created to serve five major industrial regions in the
United States, and 15 medium-size treatment plants,
each processing approximately 160,000 tons
(145,000 metric tons), would be built elsewhere to
provide reasonable access from other waste genera-
tion points. Such an array of treatment plants, taken
in conjunction with existing privately owned facil-
ities, is capable of processing all the nonradioactive
hazardous waste generated in the United States at
present, v/ith a 25-percent margin for future growth
in waste volume.
Processing reduces aqueous waste volume by about
50 percent and usually results in the elimination of
hazard (detoxification, neutralization, decontamina-
tion, etc.). If the appropriate treatment processes are
used, most processing residues will be harmless and
disposal in ordinary municipal landfills will be possi-
ble. A small portion (5 percent-225,000 tons or
204,000 metric tons) of residues containing toxic
metals would require disposal in special, secure
landfills.
Under the assumption that maximum treatment
for hazard elimination and volume reduction of
extremely hazardous waste is carried out, no more
than five (and possibly fewer) large-scale secure
landfills would be required. Facilities would transport
their toxic metal residues to such land disposal sites
rather than operating secure landfills of their own
given the scarcity of naturally secure sites, the
difficulty in gaining public acceptance of such sites,
the additional expense of artificially securing sites,
and the relatively low costs of long-haul transport.
Costs
Based on the above scenario, cost estimates have
been prepared for on- and off-site treatment facilities,
secure disposal, and waste transportation. (The actual
values used for estimation purposes are shown in
Table 8; more detail is presented in Appendix F.)
Estimates are based on comprehensive engineering
cost studies. Each regional processing facility was
assumed to provide a complete range of treatment
processes capable of handling all types of hazardous
wastes, and, therefore, each is much more costly than
existing private facilities that are more specialized.
Based on these estimates, the development of this
version of a national hazardous waste management
system would require investments in new facilities of
approximately $940 million. Average annual operat-
ing expenditures (including capital recovery, operat-
ing costs, and interest) of about $620 million would
be required to sustain the program. In addition,
administrative expenses of about $20 million annu-
ally for Federal and State regulatory programs would
be necessary.
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ISSUES OF IMPLEMENTATION
27
TABLE 8
COST ASPECTS (IN MILLIONS OF DOLLARS) OF AN EPA SCENARIO OF A
NATIONAL HAZARDOUS WASTE MANAGEMENT SYSTEM
Item
On-site facilities
Off -site facilities.
Treatment (large)
Treatment (medium)
Secure disposal
Transport
Total
Cost
Capital
needed
1.4
86.0
24.1
2.5
•"63.0
per unit
Annual
operating*
0.73
57.1
12.5
1.2
in
needed
51
5
15
5
(8)
Total
capital
required
71
430
362
13
63
*939
Total
annual
cost*
37
286
188
6
99
616
*Includes capital recovery in 10 years and interest at 7 percent.
'Capital required based on new rail rolling stock.
-! Dollars per ton.
§ Transport required for 9.0 million tons (8.25 million metric tons) of waste; average distance from generator to treatment
facility is 150 miles.
* Approximately $25 million has already been invested in current private sector off-site treatment facilities
For this scenario, system costs fall into five broad
categories' (1) on-site treatment (about 6 percent of
total costs on an annualized basis), (2) transportation
of wastes to off-site treatment facilities (16 percent),
(3) off-site treatment (74 percent), (4) secure disposal
(1 percent), (5) program administration (3 percent).
The largest element of cost is off-site treatment.
Treatment followed by land disposal of residues is
not necessarily more expensive than direct disposal of
untreated wastes in secure landfills. Treatment before
disposal would buy greater long-range protection of
public health and the environment.
Variations
Although the above scenario is reasonable and
would satisfy requirements for environmentally
adequate hazardous waste management, it is not
presented as a hard-and-fast specification of what a
national system should look like. There is no single
optimum system given such uncertainties as hazard-
ous waste generator response to air, water, and
hazardous waste regulations; future directions in
production and waste processing technology, timing
and level of enforcement, and public reaction to site
selection decisions. However, some comments can be
made about variations in the system scenario pre-
sented.
It is unlikely that more large-scale and fewer
medium-scale processing facilities would be con-
structed unless specifically mandated. The higher
initial capital investment of large-scale processing
facilities is warranted only where large market
potential exists, i.e., in the major industrial regions
At present, addition of only two more large-scale
facilities (over the five in the scenario) would provide
sufficient capacity to treat all nonradioactive hazard-
ous wastes. Stated another way, two more large-scale
facilities could handle all the wastes for which 15
medium-size facilities were postulated in the scenario.
However, resulting increased costs of transportation
from generators to these larger treatment facilities
(because average transport distances would increase)
would offset cost reductions due to better economies
of scale (Figures 3 and 4). The net result would be a
significant loss in convenience and increase in trans-
portation risks for a fairly insignificant saving in
capital cost and a higher operating cost.
Construction of a larger number of medium- or
small-scale plants (and consequently fewer large-scale
plants) tends to drive capital costs up sharply (Figure
3). Total system operating costs also rise because
transportation cost savings are not sufficient to offset
lost economies of scale (Figure 4). Transportation
risk would decline because of shorter haul distances,
but inspection and enforcement costs would increase
because of the larger number of plants requiring
surveillance. As will be discussed, however, a private
sector system may consist of more smaller plants and
thus may result in higher total costs.
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28
DISPOSAL OF HAZARDOUS WASTES
2,800
2,400
2,000
o
-o
"5 1,600
i 1,200
cfl
r-
W
O
o
800
400
L = LARGE FACILITY, PROCESS ING 1,330,000 tons (1,210,000 metric tons) per year
M -= MEDIUM FACILITY, PROCESSING 162,000 tons (147,000 metric tons) per year
S = SMALL FACILITY, PROCESSING 33,300 tons (30,200 metric tons) per year
40M +
76S
273S
20M *
176S
6L +
7M
5L t
15M
4L +
24M
3L -t
32M
2L +
40M
1L +
48 M
56M
800
851
939
1070
1 176
1234
1392
1497
1796
2246
2665
INCREASING! YSMAl LER FACILITIES
Ik-
Figure 3. Fixed capital cost sensitivity of a national hazardous waste management system to fluctuations in number and size
of facilities. Each configuration includes $71 million for on-site facilities, $13 million for secure land disposal, and from $41 million
to $114 million for new transportation equipment (based on average distance and estimated turnaround time)
1,400 i—
1,200
1,000
o
•a
in
O
O
800
600
400
2OO
L = LARGE FACILITY, PROCESSING 1,330,000 tons (1,210,000 metric tons) per year
M - MEDIUM FACILITY, PROCESSING 162,000 tons (147,000 metric tons) per year
S - SMALL FACILITY, PROCESSING 33,300 tons (30,200 metric tons) per year
273S
(1334)
20M i
176S
(1142)
OPERATING
COSTS
TRANSPORTATION
TREATMENT AND DISPOSAL
40M H-
76S
(932)
7L
(627)
184
443
6L +
7M
(603)
5L +
15M
(616)
4L i
24M
(639)
3L +
32M
(677)
2L +
40M
(714)
1L +
48M
(751)
56M
(788)
129
474
99
517
67
572
61
616
56
658
50
701
43
745
39
893
39
1103
39
1295
INCREASINGLY SMALLER FACILITIES
Figure 4. Operating cost sensitivity of a national hazardous waste management system to fluctuations in number and size of
facilities. Each configuration includes $37 million in annual costs for on-site facilities and $6 million for secure land disposal
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ISSUES OF IMPLEMENTATION
29
There could be fewer disposal sites than assumed
in the scenario if land availability and suitability and
public acceptance problems arise. This outcome is
likely if, for instance, only arid lands with no
hydrologic connection to surface and ground waters
are deemed acceptable as disposal sites; i.e., if
disposal siting standards are extremely strict. Trans-
portation costs would increase somewhat but not
linearly with distance. For example, rail transport
costs are estimated at $35 per ton for 1,000 miles and
$49 per ton for 2,000 miles. Transport risks would be
greater, but disposal risks and enforcement costs
would decline because fewer sites would be easier to
monitor.
On the other hand, as a policy decision, the
Government could allow significantly more disposal
relative to processing. Many more, or at least much
larger, disposal sites would be required in this case
since, for instance, approximately a 40-fold increase
in tonnage going to secure disposal sites would result
if processing were bypassed altogether. The total
system capital cost would be reduced since treatment
represents a large capital expense (Table 9). If
disposal siting standards were very strict such that
arid lands in the Western States were the only
acceptable sites, transportation costs would increase
substantially because of the large increase in tonnage
transported over longer distances. In fact, in this case,
annual operating costs for this "disposal only" option
exceed annual costs for the treatment and disposal
system scenario discussed.
Aside from economic considerations, what is more
important in EPA's judgment is that the disposal only
option could significantly increase public health and
environmental risk, perhaps to an unacceptable level,
given the long-term hazard of many toxic substances,
particularly if such substances are not converted to
relatively insoluble forms prior to disposal. Moreover,
transport risks would undoubtedly increase.
COST DISTRIBUTION TO USERS
Wuh the need for a hazardous waste regulatory
program and a hazardous waste management system
to implement such a program, there is the fundamen-
tal issue of who should pay for creation and
operation of the system. The two basic options are
that hazardous waste generators pay or society pays.
TABLE 9
COMPARATIVE COSTS (JN MILLIONS OF DOLLARS)
OF HAZARDOUS WASTE REGIONAL TREATMENT
VERSUS DISPOSAL ONLY
Regional treatment
costs
Disposal only
Item
Fixed Annual Fixed Annual
capital operating capital operating
Treatment''
Disposal-!-
Transportation ^
Total
863
13
63
939
511
6
' 99
616
386
252
638
_
257
490
747
*Cost data are from two large secure land disposal sites,
both in the Western States, with 10 million tons per year of
untreated hazardous wastes shipped directly to these sites.
The average distance between waste generators and secure
land disposal sites is 2,000 miles.
"t On-site treatment, 1.0 million tons; off-site treat-
ment, 9.0 million tons.
•!'Secure land disposal regional treatment, 0.225
million tons; disposal only, 10.0 million tons. Secure land
disposal costs are based on preliminary Office of Solid Waste
Management Programs estimates.
§ Indicated transportation costs represent a minimum
because bulk shipment by railroad in 10,000-gallon tank cars
was assumed for all cases.
^ Annual freight charges.
This issue hinges on the principle of equity of cost
distribution and on an assessment of ability to pay.
Equity of Cost Distribution
The usual aim in environmental legislation is to
cause costs to be internalized. Costs are internalized
when the generator pays the full costs of actions for
which he is responsible. In turn, he can either absorb
the costs ("taxing" his stockholders) or pass on the
costs in the price of his products and services (taxing
those who benefit from the use of his products and
services). Only those who have a direct relationship to
the generator are required to pay for the generator's
actions.
A publicly funded incentive distributes the costs
inequitably by assigning costs incurred by a special
group to the population at large, not in proportion to
the use of waste-related products by that public but
in proportion to income levels.
The regulatory approach internalizes the costs of
hazardous waste management. It forces generators to
pay for such management while it ensures that the
practices are environmentally acceptable The only
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30
DISPOSAL OF HAZARDOUS WASTES
portion of the program's cost that must be borne by
the public as a whole is the small portion devoted to
the actual preparation of the regulations and their
enforcement, and the management of wastes gener-
ated by the Federal Government.
The regulatory strategy, therefore, results in equit-
able cost distribution. Only those institutions and
individuals who benefit directly from the activities of
hazardous material production and consumption are
required to bear the costs of waste disposal, and the
costs borne are directly proportional to the amount
and type of wastes generated. Most hazardous wastes
are generated by industry and the Federal Govern-
ment rather than municipalities. The strategy adopted
for dealing with air and water pollution from indus-
trial sources has been the regulatory strategy. Thus,
this approach is consistent with the total thrust of
environmental control efforts. A subsidy strategy to
industry would represent a new departure.
It could be argued that if some sector of the
economy is unable to bear the costs of a regulatory
program by nature of its institutional situation, fiscal
support of that sector may be justified to enable it to
meet the regulatory requirements without serious
harm to the economy or interruption of vital services.
However, generators of most hazardous wastes are
either private, profitmaking industrial organizations
or governmental entities. Private corporations are
capable of accepting the additional costs of environ-
mental control that may be imposed by a hazardous
waste regulatory program. They have the option of
passing on such costs to their customers or absorbing
the costs by reducing the return on investment to
their owners. Government agencies have the usual
capabilities available to such entities to seek budget-
ary support for legally mandated activities. Neither
sector would fall into the hardship category if it had
to pay the full costs of its waste generation.
Analysis of Cost Impacts
No detailed study has yet been performed to
determine the cost burden of specific hazardous
waste regulations relative to the sales, costs, invest-
ment levels, and employment levels of the industrial
sectors that would be affected. Rough aggregate
calculations have been done for the following sec-
tors, chemicals, chemical products, petroleum refin-
ing, rubber production, ordnance, primary metal
industries, pulp and paper, and mining. These aggre-
gate calculations indicate that the costs of hazardous
waste management would be roughly equivalent to 1
percent of the value of product shipments. Of course,
the corresponding percent for some disaggregate
categories may turn out to be much higher.
A general principle that recurs throughout this
report is that the costs of hazardous waste manage-
ment should be internalized in the prices of the
commodities whose production has generated the
hazardous waste. This principle is consistent with the
President's environmental messages. The results of
preliminary studies do not indicate that hazardous
waste management costs would cause drastic indus-
trial disruption. EPA is giving a high priority to
detailed analysis of the costs and cost impacts of
hazardous waste management.
Benefit/Cost Analysis
Because of the cost and price impacts that
hazardous waste regulations could impose, careful
consideration is being given to benefit/cost analyses.
Hazardous waste regulations may be said to be
"benefit determined" in the sense thai they cover
situations in which the benefit to society in the form
of a hazard reduction is shown to be large. Thus, the
first type of benefit/cost comparison is that involved
in placing a hazardous waste on the regulatory list as
a result of demonstrating that some regulatory option
is preferable to the status quo. The second, and
equally important, type of benefit/cost analysis is the
comparison of all the options, each one involving
different levels of benefit and cost. One may speak
rhetorically about rendering a substance completely
harmless, but in fact that is only one option. That
option may have to be chosen in cases for which the
associated benefits are large. In other cases, benefit/
cost comparisons may support a different process
alternative. To the extent possible, EPA tends to use
benefit/cost analyses to explore the full range of
technological options for each hazardous waste.
ROLE OF THE PRIVATE SECTOR
As discussed earlier, processing economics appear
to favor off-site treatment and disposal in most
instances. A private hazardous waste services industry
exists which already offers off-site treatment and
disposal services, but currently available cff-site ca-
pacity is clearly insufficient to handle the entire
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ISSUES OF IMPLEMENTATION
31
tonnage of hazardous waste materials that would
ultimately be brought under control. In light of this,
it is obvious that off-site capacity must be signifi-
cantly expanded if environmentally adequate hazard-
ous waste treatment and disposal is to take place.
EPA believes that private industry should and will
respond to the proposed regulatory program, but
there are a number of questions related to the nature
of that response: Will adequate capacity be forth-
coming? Can environmentally sound operations be
assured? Can reasonable user charges be assured? Can
the private sector provide long-term care of treat-
ment, storage, and disposal sites? These questions are
taken up in what follows. The general issue of the
Government's role is discussed separately.
Capacity Creation
The central question is whether a regulatory
program will result in sufficient investment in new
capacity by the private sector. Basic issues of capacity
creation include the availability of investment capital
and the willingness to invest capital in view of the
risks involved, i.e., the factors influencing investment.
Related to the broad question of private investment
are other issues dealing with the availability of trained
manpower and the availability of suitable land for
facility siting.
Private Investment Sources. Under a regulatory
program, capital is likely to be available from at least
three private sources: hazardous waste service firms,
generators, and solid waste management conglomer-
ates.
In the initial stages of a regulatory program (e.g.,
the first year), no major new investments are likely to
be required. Existing service firms will respond to
new demand by increasing their throughput. Soon,
however, demand is likely to outstrip supply of such
services in a climate of vigorous enforcement, and
new investments will be required.
The ability of present service firms to provide
internal capital and to attract outside investments has
been limited because of generally poor earning
records in the past. This situation results from the
absence of regulatory and economic incentives for
generators to utilize their services. Increased regula-
tory activity, however, should improve the fiscal
abilities of these companies over time by increasing
their rate of facility utilization and (under conditions
of strong demand) by increasing the prices they can
command for services. In fact, the utilization and
earnings rates of most of these firms have been
increasing as industries respond to water pollution
control regulation. This will improve the ability of
this industry to retain earnings for investment and
also its ability to attract outside capital. This source
of capital, however, is expected to be limited in the
early years of a regulatory program.
Two other sectors of the economy, however, are
expected to become more involved in capacity
creation and to attract substantial investment capital
to the field.
Major generators of hazardous wastes (e.g., the
chemical and metal industries) will have a strong
interest in assuring that off-site facilities will be made
available for their use because off-site handling will be
more economical, These financially strong organiza-
tions-some of which already operate treatment and
disposal systems for their own use-may enter the
service field by acquisition or other routes or may
underwrite the activities of others by provision of
long-term contracts or use of other devices.
During the past 5 years, large and financially
strong private solid waste management "conglomer-
ates" have emerged, offering management services for
nonhazardous wastes. These organizations have estab-
lished strong lines of credit at attractive interest rates.
Although most of these firms lack the technical
know-how to manage hazardous wastes today, they
are likely to acquire know-how and to enter this field
under the stimulus of a regulatory program in a
logical extension of their current services to industry.
Some have already established a position in this field
by the acquisition of hazardous waste management
subsidiaries.
As a result, it is concluded that sources of private
capital to build new capacity potentially is available.
This does not mean, however, that it will be
forthcoming.
Factors Influencing Investment. Private sector
investment in hazardous waste management facilities
entails significant risks, and these risks generally
increase as the size of the proposed facilities in-
creases. There are uncertainties regarding waste gener-
ator response to air, water, and hazardous waste
regulations; generators may install new production
processes which result in fewer wastes or wastes with
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32
DISPOSAL OF HAZARDOUS WASTES
different characteristics, generators may elect to treat
wastes on site; future breakthroughs in processing
technology may render the proposed plant pre-
maturely obsolete, further environmental standards
may impact on the proposed plant; economic forces
may result in geographical shifts in waste generator
plant locations, and there are uncertainties relating to
the future activities of competitors.
These factors may (1) deter investment of any
kind, (2) lead to investment in treatment processes
only for wastes generated in high volume or for
wastes that are relatively inexpensive to treat, (3) lead
to investment in smaller, less risky facilities that are
more expensive to operate on a unit cost basis, or (4)
lead to processing plant siting only in locations where
major industrial waste sources are assured.
In view of these uncertainties, the degree and
timing of private capital investment in new capacity
will depend heavily on the quantity of waste regu-
lated and the level and timing of enforcement. Also,
the ultimate private sector network that results may
include many smaller facilities and therefore repre-
sent, in the aggregate, a more expensive system than
the scenario depicted.
Quantity of Waste Regulated. Regulations that
affect a significant tonnage of waste will spur
investments more than regulatory activity aimed at a
small proportion of the Nation's hazardous wastes.
A regulatory program is most likely to be aimed at
the control of specific waste compounds rather than
the waste streams in which the compounds occur.
Justification of regulatory action must be tied to
health and environmental effects, which can be
established most conclusively by studying the effects
associated with specific chemicals.
Unlike the regulator, the generator must dispose of
and the service firm must manage waste streams that
may contain a number of hazardous substances in
mixture.
Background studies performed for EPA have pro-
vided useful data on the composition of waste
streams. These data indicate that regulatory control
of a limited number of the most hazardous substances
could result in the treatment and disposal of a
substantial proportion of the total waste stream.
Several hazardous substances are usually present in
chemical and metallurgical hazardous waste dis-
charges, and selective treatment of one or two
components of the waste does not appear to be
economical. Not all hazardous substances must be
regulated immediately, in other words, to cause most
wastes to be treated and disposed of under controlled
conditions.
This suggests that regulatory activity can move
ahead based on regulation of groups of a few
substances at a time-in a manner similar to that
adopted to implement the hazardous effluent pro-
visions of air and water mandates-while still ensuring
that substantial quantities of hazardous wastes will be
treated.
Level and Timing of Enforcement. The key to
capacity creation appears to be vigorous enforcement
of regulations to force the use of existing capacity by
generators. Enforcement of regulations wherever
possible will impose costs on generators which may
exceed costs of treatment and disposal in new
facilities more appropriately located relative to
regions of waste generation and will build pressure for
rapid investments. Such enforcement will also create
incentives for new ventures by ensuring markets for
services.
The regulatory approach most likely to result in
private investment would be one that encouraged
incremental additions to capacity by mandating their
use as soon as they are created. The approach should
be tied to a terminal date by which all regulated
wastes must be managed as mandated.
The incremental approach has the drawback that it
initially impacts more heavily on generators that are
near existing treatment and disposal facilities. Thus,
other generators that have no such services available
to them have a potential advantage. However, this
approach protects the public and the environment as
soon as possible wherever it is possible.
The incremental approach is contrasted to a
strategy where regulations are announced at one
point in time but provide some reasonable time for
creation of capacity nationwide by generators or their
agents before any enforcement takes place. This latter
approach would provide fewer incentives for invest-
ment in increments of capacity and, by bunching
capital demand in the reasonable waiting period,
would also tax the fiscal capacities of industry to
respond. If no capacity is created by the deadline
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ISSUES OF IMPLEMENTATION
33
period, appeals to delay enforcement would be likely.
In summary, timely investment of private capital
to create capacity is anticipated if the regulatory
program affects a substantial portion of the Nation's
hazardous wastes and if a vigorous but incremental
enforcement approach over time is adopted. These
conditions will assure an investor that the facilities he
builds will be used, but will avoid excessive demands
on available capital at the outset of the program.
Government activity in some fiscal role can poten-
tially speed up timing of investments by private
service firms where high investment risks must be
overcome; this is discussed later in more detail. A
governmental fiscal role, however, is also subject to a
number of constraints.
Availability of Manpower. The technology of
hazardous waste processing is capital intensive, and a
significant increase in capacity will require only a
limited expansion of labor. Much of the expertise
required for the expansion of the hazardous waste
management industry already exists in the metallur-
gical and petrochemical industries and the engineering
and construction firms that service these. Similarly,
the skills required at local, State, and Federal levels of
government are essentially the same as those neces-
sary for the operation of air and water pollution
control programs. Capacity creation is not thought to
be constrained by a shortage of manpower under any
reasonable implementation timeframe (for example, 5
years).
Availability of Land. Land suitable for the siting
and operation of hazardous waste treatment facilities
has been identified as part of EPA's background
studies (Appendix F). There is no shortage of
appropriate land for treatment facilities in the
vicinity of or immediately within the Nation's major
hazardous waste generation regions.
Land used for disposal by burial should be secure,
i.e., it should be sealed off from underlying ground-
waters by impervious materials. Ideally, such sites
should be located in areas where cumulative precipita-
tion is less than evaporation and transpiration so that
rain cannot accumulate in the sealed landfills. Such
conditions prevail only in the western desert regions.
Ideal conditions for disposal sites need not be
present if the secure landfill is located near hazardous
waste treatment plants where water accumulations
can be removed from the disposal site and treated in
the plant. Sites with appropriate geological features
are available in areas other than the Western States.
Probably the most important potential problem
associated with the land-use aspect of hazardous
waste management is that of public resistance to the
location of such facilities in their communities.
Although EPA's public attitudes survey indicates
public support of central treatment and disposal of
hazardous wastes under controlled conditions, it is
not at all certain that the public will express the same
attitude when faced with an actual siting decision.
Although siting problems are anticipated by EPA,
there are indications that such constraints can be
overcome. The private hazardous waste management
industry and AEC contractors have been able to
obtain sites in most cases. Treatment and ultimate
disposal facilities will represent employment in areas
that are of necessity low in population density (if
sites are chosen to minimize safety hazard) and in
need of industrial development.
Environmentally Sound Operation
The private sector, following a profit motive, has
incentives to run only as good a hazardous waste
management operation as it takes to obtain and keep
business and to comply with governmental regula-
tions. Customers may demand more stringent opera-
tions to benefit their image or for legal and other
reasons, but the private sector hardly can be expected
to go all out to maximize the environmental sound-
ness of its operations.
It is anticipated, however, that environmentally
acceptable operation of private facilities can be
assured by appropriate governmental and citizen
activities. The basic standards and regulations govern-
ing hazardous waste management operations must not
only be environmentally adequate in themselves but
also must provide for effective administrative and
legal sanctions against potential offenders. Adoption
of appropriate criteria for facility licensing can filter
out candidates who do not possess resources suffi-
cient to provide sound facility construction, opera-
tion, maintenance, and surveillance. Vigorous inspec-
tion and enforcement by Government, with the
attendant threat of licensing suspension or revocation
actions, can assure sound operations over time.
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34
DISPOSAL OF HAZARDOUS WASTES
If the regulatory legislation contains provisions for
citizen suits, which is likely given the trend of recent
environmental legislation, citizens may bring legal
pressure to bear on both the Government and private
industry to force compliance with existing Federal,
State, and local regulations.
Reasonable User Charges
The issue of whether a private market situation
will result in reasonable user charges is dependent
upon quite complex interactions involving facility
scale and location, risk, competition, and transporta-
tion rates.
As has been discussed, significant economies of
scale are possible in the processing of toxic waste. To
the extent that such economies are realized and
passed on to users of processing facilities, user charges
will be reasonable. To the extent that economies of
scale are not achieved or that economies are achieved
but savings are absorbed as monopoly profits, charges
for the use of processing facilities may be unreason-
able.
Unfettered operation of the market system may
not result in the construction of plants of optimal
size initially. Because of a desire to minimize or avoid
the risk factors discussed earlier, there may be a
tendency to build a number of small, high unit cost
plants where one large economical plant would
suffice. On the other hand, although small plants may
result in higher unit costs of operation, their lower
investment requirements may spur competition and
reduce opportunities for monopoly profits. Thus, in
the scenario described earlier in which large plants
with large investment costs and low operating costs
predominate, there is potential for monopolistic
behavior and, consequently, unreasonably high prof-
its and user charges. The possibility of monopoly is
increased by the relatively few companies nationally
which have the resources and technical qualifications
to enter this field.
Factors other than the risks associated with large
investments tend to counter monopolistic behavior,
however. Given the relatively low cost of transport in
comparison to processing costs and the relative
insensitivity of transport charges to increase in haul
distances, tradeoffs between transportation charges
and at-the-plant user charges should result in some
overlap among service regions and thus should stimu-
late competition. A second potential limitation on
unreasonably high user charges is the ability of waste
generators to operate their own waste processing
plants if projected processing charges appear exces-
sive. Also, the Federal Government could use the
processing and disposal of its own wastes, which
would be sent to the low bidder on a service contract,
as leverage to keep charges reasonable. The revenue
and cost information which the Federal Government
typically requires as part of the procurement process
should itself provide a means of tracking the reason-
ableness of processing charges on a continuing basis.
Although it is difficult to predict how these
opposing forces will operate under a free market
situation, there is no indication at this time of the
need for additional Government control (beyond that
derived from Federal Government procurement) of
hazardous waste service charges. Competition exists
now in the general absence of specific hazardous
waste regulations, and additional competition is
anticipated if new regulatory legislation is passed.
Overall system costs, even if many small plants are
the rule (Figure 4), should not be so unreasonably
high that they merit Federal intervention.
Long-Term Care
As indicated earlier, some nonradioactive hazard-
ous wastes cannot be converted to an innocuous form
with presently available technology, and some resi-
dues from waste treatment processes may still be
hazardous. Such materials require special storage or
disposal and must be controlled for long periods of
time.
In some respects such materials resemble long-lived
radioactive wastes: both are toxic and retain essen-
tially forever the potential for public health and
environmental insult. There are differences, how-
ever: Nonradioactive hazardous wastes normally do
not generate heat nor do they require radiation
shielding.
Until recently, essentially all radioactive wastes
were generated by the Federal Government itself as a
result of nuclear weapon, naval propulsion, and other
programs. This established a precedent for Federal
control of radioactive wastes that has carried over to
the commercial nuclear power generation and fuel
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ISSUES OF IMPLEMENTATION
35
reprocessing industry. No such precedent exists for
nonradioactive hazardous wastes from industrial
sources.
AEC has established the policy of "engineered
storage" for long-lived radioactive wastes because of
difficulties in assuring long-term control of these
wastes if they are disposed of on or under the land or
in the ocean. Designs of such storage facilities will
vary with the nature of the wastes involved, but the
general principle is to provide long-lived container-
ized, or otherwise separated, easily retrievable storage
units. These units generally will require heat removal,
radiation shielding, surveillance, and security.
The storage and disposal facility requirements for
nonradioactive hazardous wastes are anticipated to be
less severe than for radioactive wastes since heat
removal and shielding are not required, but many of
the problems remain. Such facilities should be secure
in the sense that there are no hydrologic connections
to surface and ground waters. Long-term physical
security and surveillance of storage and land disposal
sites are required. Also, there should be contingency
plans for sealing off the facilities or removing the
wastes if hydrologic connections are subsequently
established by earthquakes or other phenomena.
From an institutional viewpoint, the private sector
is not well suited for a role in which longevity is a
major factor. Private enterprises may abandon storage
and disposal sites because of changes in ownership,
better investment opportunities, bankruptcy, or other
factors. If sites are abandoned, serious questions of
legal liability could arise. This issue led the State of
Oregon, in its recently adopted hazardous waste
disposal program, to require that all privately oper-
ated hazardous waste disposal sites be deeded to the
State and that a performance bond be posted as
condition for obtaining a license to operate such a
site.
Traditionally, waste generators pay a one-time fee
for waste disposal. If this concept were carried over
to hazardous waste disposal, private operators of
disposal sites would have to charge fees sufficient to
cover expenses of site security and surveillance for a
long, but indeterminant, time period. Another option
would be to consider hazardous waste disposal as a
form of long-term storage. Generators would then
pay rent in perpetuity. Because of such factors as
uncertainties of future market conditions and infla-
tion, neither of these options would appeal to either
the waste generator or disposer, nor would the
options preclude legal problems if either party were
to file for bankruptcy.
There are grounds, therefore, to consider the role
of the private sector in hazardous waste storage and
disposal as fundamentally different in character from
its role in hazardous waste treatment. EPA believes
that, given a regulatory stimulus, the private sector
can and will provide necessary facilities for hazardous
waste treatment that are operated in an environ-
mentally sound manner with reasonable user charges.
However, the issue of long-term care of privately
owned and operated hazardous waste storage and
disposal sites poses significant problems not easily
resolved. Some form of Federal or State intervention
may be required.
ROLE OF GOVERNMENT
The implementation strategy described assigns to
Government the limited role of promulgating and
enforcing regulations. In view of the potential prob-
lems discussed, however, a more extensive Govern-
ment role may be justified under certain circum-
stances. Options for more extensive Government
intervention which might be determined to be re-
quired include performance bonding, financial assis-
tance, economic regulation, use of Government land,
and Government ownership and operation of
facilities.
Performance Bonding
The Government could require a performance
bond of private firms as a condition for issuing a
license or permit for operation of hazardous waste
treatment or disposal facilities. The bond would help
to ensure environmentally sound operation of proc-
essing facilities and long-term care of disposal sites.
This system is used, for example, by the State of
Oregon for all hazardous waste disposal sites and by
the State of Kentucky for radioactive waste disposal
sites.
Performance bonding presents a paradox, however.
The bond must be large to be effective, but the larger
the bond, the more likely it is to inhibit investment.
Used unwisely, the performance bond concept could
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36
DISPOSAL OF HAZARDOUS WASTES
result in no private sector facilities or in a monop-
olistic situation with a very limited number of large
firms in the business.
EPA believes that a performance bonding system,
wisely applied, could be beneficial in establishing the
fiscal soundness of applicant firms. (If fiscally weak,
the firm could not be bonded.) The bonding system
could be adopted within a regulatory program in the
licensing procedures with very little, if any, cost to
Government.
Financial Assistance
Some form of fiscal support of capacity creation
may be justified if the private sector fails to invest the
capital needed for new facilities. If that happens,
environmental damage will continue and the potential
hazard to public health and safety will increase.
Current indications are that private capital will
begin to flow under a regulatory approach. It may be
argued, however, that capital flow may be slow and
uneven on a national basis. In some areas capacity
may be created, in others not. Investors might play a
wait-and-see game because of potential risks, etc. In
such a situation governmental fiscal support might
speed up implementation or ensure that all generators
have facilities available for use.
A governmental fiscal role in capacity creation is
not warranted-on equity and other grounds dis-
cussed earlier-unless capital flow is actually very
slow and adverse environmental effects are resulting
from the investment rate. If support is warranted,
various types of support are likely to have different
effects.
Indirect Support. A loan guarantee program,
probably the most indirect form of fiscal support
available, may be more effective in speeding up
implementation than direct, massive support of con-
struction. If capital is available (in the absolute sense)
but is not obtainable practically because of risks
associated with investments in such ventures, a loan
guarantee program can induce investments by remov-
ing or cushioning the risk. At the same time, such a
program would be less vulnerable to budgetary
constraints and less likely to lead to a slowdown in
private investments than direct support.
A loan program, while preferable to direct support
on equity grounds, would depend on budget avail-
ability and would act to slow down implementation.
Other indirect approaches, such as investment
incentives based on investment credits or rapid
writeoff provisions, are comparable to a loan program
in that they have a budgetary impact (by affecting
Government tax income) but would be less likely to
slow down implementation because no positive budg-
etary action would be required to implement such
support.
These approaches, much like direct support, would
be difficult to justify for a part of the Nation
only--that is, to support building of capacity only in
areas where private action is not resulting in
construction.
Direct Support. Direct fiscal support might con-
ceivably take the form of construction grants or
direct Government construction of facilities. Such
action can ensure capacity creation. Programs of this
type, even in the environmental area, have often
failed to meet originally established timing goals
because of budgetary constraints and other factors.
To the extent that local government involvement is
sought in a Federal program, a further potential for
delay is introduced. The availability of public funding
also has a stifling effect on private initiative. It is
economically unwise to invest private money if public
funds are available.
This approach, while it can guarantee that ulti-
mately capacity will be built, does not promise to be
effective in speeding up the implementation rate.
Where the objective is to provide capacities in regions
where investments are lagging, direct fiscal support is
extremely difficult to justify for only one area to the
exclusion of others.
The advisability of Government construction
support may also be viewed in the context of
Government competition with private industry. A
fledgling service industry exists. These firms would
object to the entrance of the Government into the
field as a competitor (direct Government construc-
tion) or Government action to set up competition
(grant programs). To the extent that private resources
have already been committed to this field, great care
would have to be exercised to avoid driving existing
firms out of the market with the resultant economic
loss to the Nation. It may be necessary on equity
grounds to compensate existing companies for their
in vestments-by outright purchase or post-factum
grant support. Determining the value of these
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ISSUES OF IMPLEMENTATION
37
companies' investments may be difficult in the face
of probably increasing demand for their services.
Economic Regulation
The Congress could mandate a hazardous waste
management system patterned after the public utility
concept. In this type of system, Government could
set up franchises with territorial limits and regulate
user charge rates.
The hazardous waste management field shares
many characteristics of currently regulated industries
in any case. There are public service aspects, relatively
few plants are required per region, and these facilities
are capital intensive. Further, there is potential for
natural geographic monopolies because barriers to a
second entrant in a given region are high.
Government control of plant siting, scale, and
rates could lessen the potential for environmental
impacts and provide greater incentive for private
sector investment since there would be no threat of
competition and consequently less risk of failure. On
the other hand, some companies may not enter the
field on a utility basis because of potentially lower
rate of return on investment. Further, lack of
competition could inhibit new technology
development.
Economic restrictions can be applied directly
through a governmental franchise board or commis-
sion or indirectly through administrative actions such
as licensing and permitting. Government control of
franchising shifts the burden of market determination
and related business decisions into the public sector,
which is not inherently better equipped to make such
decisions than is private industry.
Licensing and permitting of treatment and disposal
facilities appear to be better approaches for the
exercise of economic control since they can be used
to influence (rather than dictate) plant locations,
sizes, and rates. Some form of Government control
over such facilities is desirable in any case to ensure
their proper operation.
Administrative rather than direct regulatory
actions would be less costly to Government. New
legislation would be required to authorize either
direct or indirect economic sanctions.
Use of Federal or State Land
Although suitable sites for hazardous waste proc-
essing facilities are generally available to the private
sector, adverse public reaction to such sites may
preclude their use. If this occurs, it may be necessary
to make public lands available to private firms. These
lands could be leased or made available to private
firms. These lands could be leased or made available
free of charge, depending on circumstances. As noted
earlier, the State of Oregon requires that hazardous
waste facilities be located on State-owned land; other
States may elect to follow this precedent.
There are compelling reasons for the use of public
lands for hazardous waste disposal sites. The need for
long-term care of disposal sites and the potential
problems associated with private sector ownership of
such sites have been discussed previously. Publicly
owned disposal sites could be leased to private
operating firms, but legal title would remain with the
governmental body.
Use of Federal or State lands for privately
operated hazardous waste processing or disposal sites
is one means of reducing the capital cost and risk of
private sector investment while reducing environ-
mental risk as well. Conceivably, some form of
Government influence over user charges could be a
condition of the lease, in order to avoid potential
monopolistic behavior on the part of the lessee. The
initial cost to Government of these measures would
be minimal; however, Government maintenance of
disposal sites may be necessary if the lessee defaults.
Government Ownership and Operation of Facilities
The option of Government ownership and opera-
tion of facilities provides maximum control over the
economic and environmental aspects of hazardous
waste management. The issues of potential monop-
olistic behavior (and consequent unreasonably high
user charges) and long-term care of hazardous waste
disposal sites could be circumvented. Environ-
mentally sound construction and operation of proc-
essing and disposal facilities could be assured but
would be dependent on public budgets for imple-
mentation. Resource recovery could be mandated.
Public lands suitable for hazardous waste proc-
essing and disposal sites exist in the Western States
but may not be available in the Eastern States. If
Government ownership and operation of facilities is
mandated by Congress, the Government may have to
purchase private lands for this purpose. The potential
for adverse public reaction would be present.
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38
DISPOSAL OF HAZARDOUS WASTES
The Government does operate some hazardous
waste treatment, storage, and disposal facilities now,
but these are generally limited to handling wastes
generated by Government agencies. There is no
obvious advantage of Government operation of facil-
ities intended to treat and dispose of hazardous
wastes originating in the private sector. In fact, under
Government operation, there could be a tendency for
selection of more expensive technology than is
actually required and less incentive for efficient,
low-cost operation.
This option represents, of course, the maximum
cost to Government of those considered here. If use
of Government-owned and Government-operated
facilities is mandated, capital and operating costs of
processing plants can be recovered through user
charges. Some subsidy of disposal operations is likely,
however, since security and surveillance of disposal
sites are required in perpetuity.
SUMMARY
For a hazardous waste regulatory program, issues
of implementation of a nonradioactive hazardous
waste management system hinge on the incentives for
and inherent problems of private sector response and
the appropriate role of Government. Past experience
with air and water environmental regulation over
industrial processes indicates that the private sector
will invest in pollution control facilities if regulations
are vigorously enforced. EPA anticipates that similar
private sector investment in hazardous waste proc-
essing facilities will be forthcoming if a regulatory
program is legislated and enforced. There is no real
need for massive Government intervention or invest-
ment in such facilities. The makeup of a hazardous
waste processing system fully prescribed by free
market forces is difficult to predict, however.
The storage and ultimate disposal of hazardous
residues presents a significant problem of basically
different character since the private sector is not well
suited to a role of long-term care of disposal sites.
Options for Government action to mitigate this
problem include (1) making new or existing Federal-
and State-owned and Federal- and State-operated
disposal sites available to private industry; (2) leasing
Federal or State lands to the private sector, subject to
a performance bonding system, (3) allowing private
ownership and operation of storage and disposal sites,
subject to strict Federal or State controls. The
optimum control scheme will depend upon the nature
of the regulatory program, but Federal or State
control of storage and land disposal sites is clearly
implied in any case.
On balance, EPA believes that, with the possible
exception noted, the preferred approach to system
implementation is to allow the private sector system
to evolve under appropriate regulatory controls, to
monitor closely this evolution, and to take remedial
governmental action if necessary in the future.
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Section 5
FINDINGS AND RECOMMENDATIONS
FINDINGS
Under the authority of Section 212 of the Solid
Waste Disposal Act, as amended, EPA has carried out
a study of the hazardous waste management practices
of industry, Government, and other institutions in
the United States. The key findings of this study are
presented in this section.
Current management practices have adverse
effects. Hazardous waste management practices in
the United States are generally inadequate. With some
exceptions, wastes are disposed of on the land
without adequate controls and safeguards. This situa-
tion results in actual and potential damage to the
environment and endangers public health and safety.
Causes of inadequate management are economics
and absence of legislative control. The causes of
inadequate hazardous waste management are twofold.
First, costs of treating such wastes for hazard
elimination and of disposing of them in a controlled
manner are high. Second, legislation which mandates
adequate treatment and disposal of such wastes is
absent or limited in scope. The consequence is that
generators of hazardous wastes can use low-cost but
environmentally unacceptable methods of handling
these residues.
Authorities for radioactive wastes are adequate.
Under the authority of the Atomic Energy Act of
1954, as amended, the management of radioactive
wastes is placed under control. Although the actual
implementation of the act may be improved, the
legislative tools for accomplishing such an end exist.
Air and water pollution control author/ties are
adequate. The Clean Air Act of 1970 and the FWPCA
of 1972 provide the necessary authorities for the
regulation of the emission of hazardous compounds
and materials to the air and to surface waters from
point sources.
Legislative controls over hazardous waste Jand
disposal are inadequate. The legislative authorities
available for the control of hazardous waste deposi-
tion on land-and the consequent migration of such
wastes into the air and water media from land-are
not sufficient to result in properly controlled
disposal. This legislative gap literally invites the use of
land as the ultimate sink for materials removed from
air and water.
Land protection regulation is needed. In order to
close the last available uncontrolled sink for the
dumping of hazardous waste materials and thus to
safeguard the public and the environment, it is
necessary to place legislative control over the disposal
of hazardous wastes. In the absence of such control,
cost considerations and the competitive posture of
most generators of waste will continue to result in
dangerous and harmful practices with both short-
range and long-term adverse consequences.
The technology for hazardous waste management
generally is adequate. A wide array of treatment and
disposal options is available for management of most
hazardous wastes. The technology is in use today, but
the use is not widespread because of economic
barriers in the absence of legislation. Transfer and
adaptation of existing technology to hazardous waste
management may be necessary in some cases. Treat-
ment technology for some hazardous wastes is not
available (e.g., arsenic trioxide and arsenites and
arsenates of copper, lead, sodium, zinc, and potas-
sium). Additional research and development is re-
quired as the national program evolves. However, safe
and controlled storage of such wastes is possible now
until treatment and disposal technology is developed.
A private hazardous waste management industry
exists. A small service industry has emerged in the last
decade offering waste treatment services to industry
39
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40
DISPOSAL OF HAZARDOUS WASTES
and other institutions. This industry is operating
below capacity because its services are high in cost
relative to other disposal options open to generators.
The industry is judged capable of expanding over
time to accept most of the Nation's hazardous wastes.
Hazardous waste management system costs are
significant. Estimates made by EPA indicate that
investments of about $940 million and operating
costs (including capital recovery) of about $620
million per year will be required to implement a
nationwide hazardous waste management system
which combines on-site (point of generation) treat-
ment of some wastes, off-site (central facility) treat-
ment for hazard elimination and recovery, and secure
land disposal of residues which remain hazardous
after treatment.
The private sector appears capable of responding
to a regulatory program. Indications are that private
capital will be available for the creation of capacity
and that generators of waste will be able to bear the
costs of management under new and more exacting
rules. Private sector response to a demand created by
a regulatory program cannot be well defined, how-
ever, and the characteristics of the resulting
hazardous waste management system cannot be
definitely prescribed. Uncertainties inherent in a
private sector system include availability of capital
for facility construction and operation in a timely
manner for all regions of the Nation, adequacy of
facility locations relative to waste generators such as
to minimize environmental hazard and maximize use,
reasonableness of facility use charges in relation to
the cost of services, and long-term care of hazardous
waste storage and disposal facilities (i.e., such facil-
ities will be adequately secured for the life of the
waste, irrespective of economic pressures on private
site operators).
Several alternatives for Government action are
available if such actions are subsequently determined
to be required: If capital flow was very slow and ad-
verse environmental effects were resulting from the
investment rate, financial assistance would be possible
in indirect forms such as loans, loan guarantees, or
investment credits, or direct forms such as construc-
tion grants. If facility location or user charge problems
arose, the Government could impose a franchise sys-
tem with territorial limits and user charge rate con-
trols. Long-term care of hazardous waste storage and
disposal facilities could be assured by mandating use
of Federal or State land for such facilities.
RECOMMENDATIONS
Based on the findings, it is recommended that
Congress enact national legislation mandating safe
and environmentally sound hazardous waste manage-
ment.
EPA has proposed such legislation to Congress,
embodying the conclusions of studies carried out
under Section 212 of the Solid Waste Disposal Act.
The proposed Hazardous Waste Management Act
of 1973 calls for authority to regulate the treatment
and disposal of hazardous wastes. A copy of the
proposed act is presented in Appendix G. The key
provisions of the proposed legislation are the follow-
ing: (1) authority to designate hazardous wastes by
EPA, (2) authority to regulate treatment and disposal
of selected waste categories by the Federal Govern-
ment at the discretion of the Administrator of EPA;
(3) authority for the setting of Federal treatment and
disposal standards for designated waste categories; (4)
State implementation of the regulatory program
subject to Federal standards in most cases; (5)
authority for coordination and conduct of research,
surveys, development, and public education.
EPA believes that no further Government inter-
vention is appropriate at this time. It is EPA's
intention to carry on its studies and analyses, EPA
may make further recommendations based on these
continuing analyses.
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Appendix A
IMPACT OF IMPROPER HAZARDOUS WASTE MANAGEMENT
ON THE ENVIRONMENT
Improper management of hazardous materials or
wastes is manifested in numerous ways. Waste dis-
charges into surface waters can decimate aquatic
plant and animal life. Contamination of land and
groundwaters can result from improper storage and
handling techniques, accidents in transport, or indis-
criminate disposal acts.
A few of the many cases documented by EPA
which illustrate hazardous waste mismanagement are
listed categorically in the following compilation. Most
of these examples are water pollution related because
there have been more monitoring and enforcement
actions in this area.
WASTE DISCHARGE HAZARDS
Improper Arsenic Disposal
Because of the lack of treatment and recovery
facilities, arsenic waste materials generally are dis-
posed of by burial. This practice presents future
hazards since the material is not rendered harmless.
As a result of arsenic burial 30 years ago on
agricultural land in Perham, Minnesota, several people
who recently consumed water contaminated by the
deposit were hospitalized. The water came from a
well that was drilled near this 30-year-old deposit of
arsenic material. Attempts to correct this contamina-
tion problem are now being studied. Proposed
methods of approach include (1) excavating the
deposit and contaminated soil and diluting it by
spreading it on adjacent unused farmland, (2)
covering the deposit site with a bituminous or
concrete apron to prevent groundwater leaching, (3)
covering the deposit temporarily and excavating the
soil for use as ballast in future highway construction
in the area, (4) excavating the material and placing it
in a registered landfill. None of these methods is
particularly acceptable since the hazardous property
of the material is not permanently eradicated, but
they at least protect the public health and safety in
the short run.
Lead Waste Hazard
Annual production of organic lead waste from
manufacturing processes for alkyl lead in the San
Francisco Bay area amounts to 50 tons (45.4 metric
tons). This waste was previously disposed of in ponds
at one industrial waste disposal site. Attempts to
process this waste for recovery resulted in alkyl lead
intoxication of plant employees in one instance, in
another instance, not only were plant employees
affected, but employees of firms in the surrounding
area were exposed to an airborne alkyl lead vapor
hazard. Toll collectors on a bridge along the truck
route to the plant became ill from escaping vapors
from transport trucks. Currently, the manufacturers
that generate organic lead waste are storing this
material in holding basins at the plants pending
development of an acceptable recovery process.
Cyanide and Phenol Disposal
A firm in Houston, Texas, as early as 1968 was
made aware that its practice of discharging such
hazardous wastes as cyanides (25.40 pounds per day,
or 11.5 kilograms per day), phenols (2.1 pounds per
day, or 0.954 kilogram per day), sulfides, and
ammonia into the Houston ship channel was creating
severe environmental debilitation. The toxic wastes in
question are derived from the cleaning of blast
furnace gas from coke plants. According to expert
testimony, levels as low as 0.05 milligram per liter of
cyanide effluent are known to be lethal to shrimp and
small fish of the species found in the Galveston Bay
area.
41
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42
DISPOSAL OF HAZARDOUS WASTES
Alternative disposal methods involving deep-well
injection were recommended by the firm and the
Texas Water Quality Board. EPA rejected this
proposal and the firm in question was enjoined by the
courts to cease and desist discharging these wastes
into the ship channel. Subsequently, the courts have
ruled in favor of EPA that deep-well injection of
these wastes is not an environmentally acceptable
disposal method at this site.
Arsenic Contamination
A chemical company in Harris County, Texas, that
produces insecticides, weed killers, and similar
products containing arsenic has been involved in
litigation over the discharge of arsenic waste onto the
land and adjacent waters. Charges indicate that waste
containing excessive arsenic was discharged into, or
adjacent to, Vince Bayou causing arsenic-laden water
drainage into public w.uers. This company and its
predecessor have a long history of plant operation at
this site. Earlier, waste disposal was accomplished by
dumping the waste solids in open pits and ditches on
Company property. This practice was abandoned in
1967 in favor of a proposed recycling process.
However, as of August 1971, actions were taken on
behalf of the county to enjoin manufacturing opera-
tions at the plant because of alleged excessive arsenic
discharge into the public waters. No other informa-
tion is available regarding the current status of court
actions or disposal practices.
Insecticide Dumping
Mosco Mills, Missouri. In mid-1970, an applicator
rinsed and cleaned a truck rig after dumping unused
Endrin into the Cuivre River at Mosco Mills, Missouri.
This act resulted in the killing of an estimated
100,000 fish, and the river was closed to fishing for 1
year by the Missouri Game and Fish Commission.
Waterloo, Iowa. In rnid-1972, a chemical manu-
facturing company in Waterloo, Iowa, burned tech-
nical mevinphos (phosdrin), resulting in gross con-
tamination to the plant area. Approximately 2,000
pounds (908 kilograms) of previously packaged
material were dumped and left for disposal. After
discussion with EPA Region VII office personnel and
appropriate Iowa agencies, the area was neutralized
with alkali and certain of the materials were repack-
aged for disposal by a private hazardous waste
disposal firm in Sheffield, Illinois.
Trace Phenol Discharge
During 1970, the Kansas City, Missouri, water
supply contained objectionable tastes and odors due
to a phenolic content. It was alleged, and subsequent
investigation indicated, that fiber-glass waste dumped
along the river bank upstream was the source of the
tastes and odors. The waste was coated with phenol
and was possibly being washed into the river. Action
was taken to have the dump closed and sealed.
Discharge of Hydrocarbon Gases Into River
In July 1969, an assistant dean at the University of
Southern Mississippi died of asphyxiation while
fishing in a boat in the Leaf River near Hattiesburg,
Mississippi. The victim's boat drifted into a pocket of
propane gas that reputedly had been discharged into
the river through a gasline terminal wash pipe from a
petroleum refinery.
Cyanide Discharge
Part of the Lowry Air Force Base Bombing Range,
located 15 miles (24.1 kilometers) east of Denver,
was declared surplus and given to Denver as a landfill
site. As of July 1972, the Lowry site was accepting,
with the exception of highly radioactive wastes, any
wastes delivered without inquiry into the contents
and without keeping anything more than informal
records of quantities delivered.
Laboratory tests of surface drainage have indicated
the presence of cyanide in ponded water downstream
from the site. Significant amounts of cyanide are
discharged in pits at the disposal site, according to the
site operator. Short-lived radioactive wastes from a
nearby medical school and a hospital are also
accepted at this site. These wastes are apparently well
protected but are dumped directly into the disposal
ponds rather than being buried separately.
The Denver County commissioners received a
complaint that some cattle had died as the result of
ingesting material washed downstream from this site.
Authorities feel this occurred because of runoff
caused by an overflow of the disposal ponds into
nearby Murphy Creek after a heavy rainstorm.
Arsenic Dump: Groundwater Contamination
A laboratory company in the north-central United
States has been utilizing the same dump site since
1953 for solid waste disposal. Of the total amount
(500,000 cubic feet or 14,150 cubic meters) dumped
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IMPACT OF IMPROPER HAZARDOUS WASTE MANAGEMENT ON THE ENVIRONMENT
43
as of 1972, more than half is waste arsenic. There are
several superficial monitoring wells (10 to 20 feet
deep or 3.05 to 6.10 meters deep) located around the
dump site. Analyses of water samples have produced
an arsenic content greater than 175 parts per million.
The dump site is located above a limestone bedrock
aquifer, from which 70 percent of the nearby city's
residents obtain their drinking and crop irrigation
water. There are some indications that this water is
being contaminated by arsenic seepage through the
bedrock.
Poisoning of Local Water Supply
Until approximately 2 years prior to June 1972,
Beech Creek, Waynesboro, Tennessee, was considered
pure enough to be a source of drinking water. At that
time, waste polychlorinated biphenyls (PCB) from a
nearby plant began to be deposited in the
Waynesboro city dump site. Dumping continued until
April 1972. Apparently the waste, upon being off-
loaded at the dump, was pushed into a spring branch
that rises under the dump and then empties into
Beech Creek. Shortly after depositing of such wastes
began, an oily substance appeared in the Beech Creek
waters Dead fish, crawfish, and waterdogs were
found, and supported wildlife also was being affected
(e.g., two raccoons were found dead). Beech Creek
had been used for watering stock, fishing, drinking
water, and recreation for decades. Presently, the
creek seems to be affected for at least 10 miles (16.09
kilometers) from its source and the pollution is
moving steadily downstream to the Tennessee River.
Health officials have advised that the creek should be
fenced off to prevent cattle from drinking the water.
MISMANAGEMENT OF WASTE MATERIALS
In the presence of locally imposed air and water
effluent restrictions and prohibitions, industrial con-
cerns attempt to manage disposal problems by
storage, stockpiling, and lagooning. In many
instances, the waste quantities become excessive and
environmental perils evolve as a result of leaching
during flooding or rupturing of storage lagoons.
Reported instances of this type of waste management
pioblem are shown in the following.
Fish Kill
On June 10, 1967, a dike containing an alkaline
waste lagoon for a steam generating plant at Carbo,
Virginia, collapsed and released approximately 400
acre-feet (493,400 cubic meters) of fly ash waste into
the Clinch River. The resulting contaminant slug
moved at a rate of 1 mile per hour (1.6 kilometers per
hour) for several days until it reached Norris Lake in
Tennessee, whereupon, it is estimated to have killed
216,200 fish. All food organisms in the 4-mile
(6.43-kilometer) stretch of river immediately below
Carbo were completely eliminated. The practice of
waste disposal by lagooning is a notoriously inade-
quate method which lends itself to negligence and
subsequent mishaps.
Phosphate Slime Spill
On December 7, 1971, at a chemical plant site in
Fort Meade, Florida, a portion of a dike forming a
waste pond ruptured, releasing an estimated 2 billion
gallons (7.58 billion liters) of slime composed of
phosphatic clays and insoluble hahdes into Whidden
Creek. Flow patterns of the creek led to subsequent
contamination of the Peace River and the estuarine
area of Charlotte Harbor. The water of Charlotte
Harbor took on a thick milky white appearance.
Along the river, signs of life were diminished, dead
fish were sighted, and normal surface fish activity was
absent. No living organisms were found in Whidden
Creek downstream of the spill or in the Peace River at
a point 8 miles downstream of Whidden Creek. Clam
and crab gills were coated with the milky substance,
and in general all benthic aquatic life was affected in
some way.
Mismanagement of Heterogeneous Hazardous Waste
A firm engaged in the disposal of spent chemicals
generated in the Beaumont-Houston area ran into
considerable opposition in Texas and subsequently
transferred its disposal operations to Louisiana In
October 1972, this firm was storing and disposing of
toxic chemicals at two Louisiana locations. De
Ridder and De Quincy. At the De Ridder site, several
thousand drums of waste (both metal- and
cardboard-type, some with lids and some without)
were piled up at the end of an airport runway apron
within a pine tree seed orchard. Many of the drums
were popping their lids and leaking, and visible vapors
were emanating from the area The pine trees beside
the storage area had died. At the same time, the firm
was preparing to bury hundreds of drums of hazard-
ous wastes at the De Quincy location, which is
considered by EPA to be hydrogeologically
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44
DISPOSAL OF HAZARDOUS WASTES
unsuitable for such land disposal. Finally, court
action enjoined this firm from using the De Ridder
and De Quincy sites; however, the company has just
moved its disposal operations near Villa Platte in
Evangeline Parish, where the same problems exist.
Arsenic Waste Mishap
Since August 1968, a commercial laboratory in
Myerstown, Pennsylvania, has disposed of its arsenic
waste by surface storage within the plant area (form
of waste materials not known). This practice appar-
ently has led to contamination of the ground and
subsequent migrations into groundwaters through
leaching, ionic migration actions, etc., abetted by the
geologic and edaphic character of the plant site. In
order to meet discharge requirements and/or
eliminate the waste hazard, the company has had to
design and construct a system of recovery wells to
collect the arsenic effluent from groundwaters in the
area. Recovered arsenic and current arsenic waste
(previously stored on the land) are now retained in
storage lagoons. Presumably, the sludge from these
lagoons is periodically reclaimed in some way.
Lagoons of this type are generally not well attended
. and frequently result in environmental catastrophes.
Contaminated Grain
Grant' County, Washington. In 1972, mercury-
treated grain was found at the Wilson Creek dump in
Grant County, Washington, by an unsuspecting
farmer. He hauled it to his farm for livestock feed.
The episode was discovered just before the farmer
planned to utilize the grain.
Albuquerque, New Mexico. Three children in an
Albuquerque, New Mexico, family became seriously
ill, in 1970, after eating a pig that had been fed corn
treated with a mercury compound. Local health
officials found several bags of similarly treated corn
in the community dump.
Radioactive Waste
Low-level radioactive waste is lying exposed on
about 10 acres (4.05 hectares) of ground in Stevens
County, Washington, and is subject to wind erosion.
The waste comes from an old uranium processing
mill. County and State officials are concerned
because, although it is of low radioactivity level, it is
the same type that caused the public controversy at
Grand Junction, Colorado.
Waste Stockpiling Hazard: Two Cases
King County, Washington: Case 1. All types of
waste chemicals have been dumped into the old
Dodgers No. 5 Coal Mine shaft in King County,
Washington, for years. Much of this practice has
stopped but sneak violations still occur.
King County, Washington: Case 2 In the same
county, expended pesticides that are very susceptible
to fire have been stored in old wooden buildings in
the area. Several fires have occurred. In addition,
large numbers of pesticide containers have been
stacked at open dumps.
Chlorine Holding Pond Breach
A holding pond and tanks at a chemical manu-
facturing plant in Saltville, Virginia, failed, spilling
chlorine, hypochlorites, and ammonia into the north
fork of the Holston River. River water samples
showed concentration levels at 0.5 part per million
hypochlorite and 17.0 parts per million of fixed
ammonia. Dead fish were sighted along the path of
the flow in the river.
Malpractice Hazard
Several drums of a 15-year-old chemical used for
soil sterilization were discovered in the warehouse of
the weed control agency in Bingham County, Idaho.
The chemical was taken to a remote area where it was
exploded with a rifle blast. Had it been disturbed
only slightly while in storage, several people would
have been killed.
Explosive Waste
In .Kitsap County, Washington, operations at a
naval ammunition depot involved washing RDX (a
high explosive) out of shells from 1955 to 1968, and
the resulting wash water went into a dump. In routine
monitoring of wells in the area, the RDX was found
in the groundwater and in several cases the concentra-
tions exceed the health tolerance level of 1 part per
million.
Unidentified Toxic Wastes
A disposal company undertook to dispose of some
drums containing unidentified toxic residues. Instead
of properly disposing of this material, the company
dropped these drums at a dump located in Cabayon,
Riverside County, California. Later, during a heavy
flood, the drums were unearthed, gave off poisonous
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IMPACT OF IMPROPER HAZARDOUS WASTE MANAGEMENT ON THE ENVIRONMENT
45
gases, and contaminated the water. Steps were taken
to properly dispose of the unearthed drums.
Container Reclamation
At a drum reclaiming plant in northern California,
15 men were poisoned by gases given off from
drums. It is presumed that this incident occurred
because of inadequate storage procedures by the
company involved.
Stockpiling of Hazardous Waste
Several sheep and cattle and a foxhound died, and
many cattle became seriously affected, on two farms
close to a factory producing rodenticides and pesti-
cides in Great Britain. (This case illustrates the
similarity of problems that exist in highly industri-
alized nations.) The drainage from the factory led
into a succession of ponds to which the animals had
unrestricted access and from which they are therefore
likely to have drunk. Investigations showed that a
field on the site was a dumping ground for large metal
drums and canisters, many of which had rusted away,
and their contents were seeping into the ground.
Residues from the manufacture of fluoroacetamide
were dumped on the site and percolated into the
drainage ditches leading to the farm ponds. Veteri-
nary evidence indicated the assimilation of fluoro-
acetamide was possible if the animals had drunk
contaminated water. Ditches and ponds were dredged
and the sludge deposited on a site behind the factory.
All sludges and contaminated soil were subsequently
excavated, mixed with cement, put into steel drums
capped with bitumen, and dumped at sea. The
presence of fluoroacetamide in the soil and associated
water samples persisted at very low but significant
levels and thus delayed the resumption of normal
farming for nearly 2 years.
Pesticides in Abandoned Factory
In the summer of 1972, approximately 1,000
pounds (454 kilograms) of arsenic-containing pesti-
cide were discovered in an abandoned factory build-
ing in Camden County, New Jersey. The building
used to belong to a leather tannery that had
discontinued its operations.
Ground water Contamination by Chromium- and
Zinc-Containing Siudge
An automobile manufacturing company in the
New York area is regularly disposing of tank truck
quantities of chromium- and zinc-containing sludge
through a contract with a trucking firm that in turn
has a subcontract with the owner of a private dump,
The sludge is dumped in a swampy area, resulting in
contamination of the groundwater. The sludge consti-
tutes a waste residue of the automobile manufac-
turer's paint priming operations.
Disposal of Chromium Ore Residues
A major chemical company is currently depositing
large quantities of chromium ore residues on its own
property in a major city on the East Coast. These
chromium ore residues are piled up in the open,
causing probable contamination of the groundwater
by leaching into the soil.
Dumping of Cadmium-Containing Effluents Into
the Hudson River
A battery plant in New York State for years was
dumping large amounts of cadmium-containing
effluents into the Hudson River. The sediment
resulting from the plant's effluents contained about
100,000 parts per million of cadmium. The firm now
has agreed to deposit these toxic sediments in a
specially insulated lagoon.
Pesticide Poisoning
On July 3, 1972, a Z'/z-year-old child in Hughes,
Arkansas, became ill after playing among a pile of
55-gallon (208-liter) drums. He was admitted to the
hospital suffering from symptoms of organo-
phosphate poisoning. The drums were located
approximately 50 feet (15 meters) from the parents'
front door on city property. The city had procured
the drums from an aerial applicator to be used as
trash containers. The residents were urged to pick up
a drum in order to expedite trash collection. It has
been determined that these drums contained various
pesticides, including methyl parathion, ethyl
parathion, toxaphene, DDT, and others. The con-
tainers were in various states of deterioration, and
enough concentrate was in evidence to intoxicate a
child or anyone else who came into contact with it.
Improper Disposal of Aldrin-Treated Seed
and Containers
On July 9, 1969, in Patterson, Louisiana, the
owner of a farm noticed several pigs running out of a
cane field; some of the animals appeared to be
undergoing convulsions. It appears that aldrin-treated
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46
DISPOSAL OF HAZARDOUS WASTES
seed and containers had been dumped on the land in
a field and that the pigs, running loose, had encoun-
tered this material. Eleven of the pigs died. Analysis
of rumen contents showed 230.7 parts per million
aldrin and J .13 parts per million dieldrin.
Improper Pesticide Container Disposal
In May 1969, in Jerome, Idaho, Di-Syston was
incorporated into the soil in a potato field. The
''empty" paper bags from the pesticide were left in
the field, and the wind blew them into the adjacent
pasture. Fourteen head of cattle died, some with
convulsions, after licking the bags. Blood samples
showed 0.0246 part per million Di-Syston.
Ocean Dumping of Chemical Waste
The Houston Post reported in December 1971 that
large quantities of barrels containing chemical wastes
had turned up in shrimpers' nets in the Gulf of
Mexico approximately 40 miles (64.3 kilometers) off
the Texas coastline. In addition to physical damage to
nets and equipment caused by the barrels, the
chemical wastes caused skin burning and eye irri-
tation among exposed shrimper crewmen. Recovered
barrels reportedly bore the names of two Houston-
area plants, both of which apparently had used a
disposal contractor specializing in deep-sea disposal
operations.
RADIOACTIVE WASTE DISPOSAL
National Reactor Testing Station
In October 1968, the Idaho Department of Health
and the former Federal Water Quality Administration
made an examination of the waste treatment and
disposal practices at the AEC National Reactor
Testing Station (NRTS) near Idaho Falls, Idaho.
There were three types of plant wastes being gener-
ated, radioactive wastes, chemical or industrial
wastes, and sanitary wastes. It was found that there
were no observation wells to monitor the effects of
ground burial on water quality, that low-level radio-
active wastes were being discharged into the ground-
water, that chemical and radioactive wastes had
degraded the groundwater beneath the NRTS, and
that some sanitary wastes were being discharged into
the groundwater supply by disposal wells.
In a report issued in April 1970, authorities
recommended that AEC abandon the practice of
burying radioactive waste above the Snake Plain
aquifer, remove the existing buried wastes to a new
site remote to the NRTS and hydrologically isolated
from groundwater supplies, and construct observation
wells needed to monitor the behavior and fate of the
wastes.
Decommissioning of AEC Plant
The Enrico Fermi nuclear reactor just outside of
Detroit is closing. However, there still remains a
substantial waste management problem. The owner of
the plant has set aside $4 million for decommis-
sioning the plant. A preliminary decommissioning
plan and cost estimate have been submitted to AEC.
However, AEC acknowledges that costs and proce-
dures for decommissioning are still unknown since
few nuclear plants (and never one such as Fermi) have
been decommissioned. As of this date, an answer is
still being sought to this waste disposal problem.
Nuclear Waste Disposal
After a fire on May 11, 1969, at the Rocky Flats
plutonium production plant near Denver, Colorado, it
was discovered that since 1958 the company that
operated the plant had been storing 55-gallon drums
of laden oil contaminated with measurable quantities
of plutonium outside on pallets. The drums corroded
and the plutonium-contaminated oils leaked onto the
soil in the surrounding area. Soil sample radioactivity
measurements made in 1970 and 1971 at various
locations on the Rocky Flats site indicated that the
contamination of the surrounding area was 100 times
greater than that due to worldwide fallout. The
increase in radioactivity as defined by the health and
safety laboratory of AEC was attributed to the
plutonium leakage from the stored 55-gallon drums
rather than any plutonium that might have been
dispersed as a result of the 1969 fire. Later, the area
where the plutonium-contaminated laden oil was
spilled was covered with a 4-inch slab of asphalt and
isolated by means of a fence. The 55-gallon drums
were moved to a nearby building and the plutonium
was salvaged from the oil. The oil was dewatered and
solidified into a greaselike consistency. Then the
drums and the solidified oil were sent to and buried
at the NRTS at Idaho Falls, Idaho.
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Appendix B
HAZARDOUS WASTE STREAM DATA
Identifying and quantifying the Nation's hazard-
ous waste streams proved to be especially formidable
because historically there has been little interest in
quantifying specific amounts of waste materials, with
the exception of radioactive wastes.
Distribution and volume data by Bureau of Census
regions were compiled on those nonradioactive waste
streams designated as hazardous (Table 10). The
approach used is predicated on the assumption that
the hazardous properties of a waste stream will be
those of the most hazardous pure compound within
that waste stream. Wastes containing compounds with
values more than or equal to threshold levels
established for the various hazardous properties are
classified as hazardous. This approach takes advantage
of the available hazard data on pure chemicals and
avoids speculation on potential compound inter-
actions within a waste stream. A list follows to
illustrate types of chemical compounds in the
Nation's waste streams that could be regarded as
hazards to public health and the environment:
Miscellaneous inorganics
Ammonium chromate
Ammonium dichromate
Antimony pentafluoride
Antimony trifluoride
Arsenic trichloride
Arsenic trioxide
Cadmium (alloys)
Cadmium chloride
Cadmium cyanide
Cadmium nitrate
Cadmium oxide
Cadmium phosphate
Cadmium potassium cyanide
Cadmium (powdered)
Cadmium sulfate
Calcium arsenate
Calcium arsenite
Calcium cyanides
Chromic acid
Copper arsenate
Copper cyanides
Cyanide (ion)
Decaborane
Diborane
Hexaborane
Hydrazine
Hydrazine azide
Lead arsenate
Lead arsenite
Lead azide
Lead cyanide
Magnesium arsenite
Manganese arsenate
Mercuric chloride
Mercuric cyanide
Mercuric diammonium chloride
Mercuric nitrate
Mercuric sulfate
Mercury
Nickel carbonyl
Nickel cyanide
Pentaborane-9
Pentaborane-11
Perchloric acid (to 72 percent)
Phosgene (carbonyl chloride)
Potassium arsenite
Potassium chromate
Potassium cyanide
Potassium dichromate
Selenium
Silver azide
Silver cyanide
47
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48
DISPOSAL OF HAZARDOUS WASTES
Sodium arsenate
Sodium arsenite
Sodium bichromate
Sodium chromate
Sodium cyanide
Sodium monofluoroacetate
Tetraborane
Thallium compounds
Zinc arsenate
Zinc arsenite
Zinc cyanide
Halogens and interhalogens
Bromine pentafluoride
Chlorine
Chlorine pentafluoride
Chlorine trifluoride
Fluorine
Perchloryl fluoride
Miscellaneous organics
Acrolein
Alkyl leads
Carcinogens
Copper acetoarsenite
Copper acetylide
Cyanunc triazide
Diazodinitrophenol (DDNP)
Dieldrin
Dimethyl sulfate
Dinitrobenzene
Dmitro cresols
Dinitrophenol
Dinitrotoluene
Dipentaerythritol hexanitrate (DPEHN)
Gelatinized nitrocellulose (PNC)
Glycol dinitrate
Gold fulminate
Lead 2,4-dinitroresorcinate (LDNR)
Lead styphnate
Mannitol hexanitrate
Mercury compounds (organic)
Methyl parathion
Nitroaniline
Nitrocellulose
Nitroglycerin
Parathion
Picric acid
Potassium dinitrobenzfuroxan (KDNBF)
Silver acetylide
Silver tetrazene
Tetrazene
VX fethoxymethylphosphoryl-JV,N-
dipropoxy-(2,2)-thiocholme |
Organic halogen compounds
Aldrin
Chlordane
Chlorinated aromatics
Chloropicrin
Copper chlorotetrazole
DDD
DDT
2,4-D (2,4-dichlorophenoxyacetic acid)
Demeton
Endnn
Ethylene bromide
Fluorides (organic)
GB | propoxy-(2)-methylphosphoryl
fluoride)
Guthion
Heptachlor
Lewisite (2-chloroethenyl dichloro-
arsme)
Lindane
Methyl bromide
Methyl chloride
Nitrogen mustards (2,2',2"-
trichlorotriethylamine)
Pentachlorophenol
Polychlorinated biphenyls (PCB)
Tear gas (CN) (chloroacetophenone)
Tear gas (CS) (2-chlorobenzylidene
malononitrile)
It should be noted that this list is not an authoritative
enumeration of hazardous compounds but a sample
list which will be modified on the basis of further
studies. Compounds on the list should not be
construed as those to be regulated under the pro-
posed Hazardous Waste Management Act. Table 11
identifies those radioactive isotopes that are con-
sidered hazardous from a disposal standpoint.
Detailed data sheets describing the volumes, constit-
uents, concentrations, hazards, disposal techniques,
and data sources for each waste stream are available
in EPA Contract No. 68-01-0762.
-------
HAZARDOUS WASTE STREAM DATA
49
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(nitric acid)
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wastes
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production wastes
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wastes (DOD)
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LLJ
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-------
50
DISPOSAL OF HAZARDOUS WASTES
•Q
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-------
HAZARDOUS WASTE STREAM DATA
51
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to
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from refine
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CN CN
to to |
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-------
52
DISPOSAL OF HAZARDOUS WASTES
o
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if
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0 0
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p. p.
0 0
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CS CM
•&
•d .
Chromate wastes from pigments an
Arsenic wastes from purification of
^
M* o
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c 'c
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43 3
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3- 33-- 33- 33ra----- 3
of x of aT x x oT oT x oTIToxxxxx S1
2 « 2 2 oj cs 2 2 (N 2 2 2 M cs cs M cs 7,
soo ;vOc^r* I/>LOCN j , [cococococo ]
OO OOO r~< ,-< — i OOOOO
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w
(arsenites)
Electrical fuse manufacturing waste
Beryllium salt production \wsstes
Thallium production wastes
00 1
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ooo
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q o p
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in to to
i— i r—i i~-i
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Rotogravure printing plate wastes
Computer manufacturing wastes
Electronic tube production wastes
3" " 3
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co to to ^r
Magnetic tape production wastes
Battery manufacturing wastes
Mercury cell battery wastes
Railroad engine cleaning
J3 3 £i
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Z Z Z CN
OJ V
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ic (insuffiaent quantity or distnbut
Spent wood -pre serving hquors
Off -specification "agent orange" de
c
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6
-------
HAZARDOUS WASTE STREAM DATA
53
QJ QJ
3 3
ft fO
3 f3
O S
2 S
p
1
1
1
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g
o
u.
Paint stripping wastes, Vance Aii
Oklahoma
Subtotal
>,
o
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- Is
"g ° S
o
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s
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— ~— 33t-3<~- 3 5 3 ' 3 3 n * 3 « —
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CN .-H CN Z Z to S to Z 5 Z to 2 co *? Z to ^ CN
c^ o oo i i ^r co [
p p o ^ o o o
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CN T}- ' ' procs >>>>>
O O 0 O O 0
25S 2 • 2 S ' 22Z22
O O O CN O
"— ' ^O LO O | ] ^-* U7
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•— ' O LO O | CO I uO .
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poo poo
cocoooco coor* rH^-ioo c*- r^r--t*-
CS(NCSCS CS^O^ OOCS O^ O^O^O^il
» . 8 |t f ? 1 all
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ex QJ R co .-
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+-> g > i- C w
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§m^o'~3^ T3O
» a S a TS ^^J
lipli II
|S°-Eii6 "2|
« i 1 s S:a" . &^
*This is an updated version of th
tNE = New England Connectic
h Central: Illinois, Indiana, MichK
ntic: Delaware, District of Columt
Tennessee; WSC = West South Cei
(Pacific)' Alaska, California, Haw<
J Exists but quantity is unknown
§ Total liquid discharge for the la
H Percentage for the Mountain an
SI'S S
Z < S 5
-------
54
DISPOSAL OF HAZARDOUS WASTES
TABLE 11
POTENTIALLY HAZARDOUS RADIONUCLIDES*
Nuclide
H-3
Be- 10
C-14
Na-22
Cl-36
Ar-39
Ca-41
Ca-45
V-49
Mn-54
Fe-55
Co-60
Ni-59
Ni-63
Se-79
Kr-85
Sr-90-f
Zr-93"!
Nb-93m
Nb-94
Mo-93
Tc-99
Ru-106!"
Rh-102m
Pd-107
Ag-llOm
Cd.109
Cd-113m
Sn-121m
Sn-123
Sn-126
Sb-125
Te-127m
1-129
Cs-134
Cs-135
Cs-137'l-
Ce-144!
Pm-146
Pm-147
Half -life (years)
12.33
1,600,000
5,730
2.601
301,000
269
130,000
.447
.907
.856
2 7
5.27
80,000
100
65,000
10.73
29
950,000
12
20,000
3,000
213,000
1.011
.567
6,500,000
.690
1.241
14.6
50
353
100.000
2.73
.299
15,900,000
2.06
2,300,000
30.1
.779
5.53
2.5234
Sourcet
1,2,3
2
2
2
2
2
2
2
2
2
2
2, 3
2
2
1
1
1, 3
1
1,2
2
2
1
1,3
1
1
1
1
1
1
1
1
1,2
1
1
1
1
1, 3
1, 3
1
1, 3
Nuclide
Sm-151
Eu-152
Eu-154
Eu-155
Gd-153
Ho-166m
Tm-170
Ta-182
W-181
Ir-192m
Pb-210-"
Bi-210
Po-210
Ra-226:f
Ra-228 f
Ac-227-t
Th-228t
Th-229T
Th-230"!-
Pa-231-t
U-2321-
U-233t
U-234t
U-236
Np-237
Pu-236-1'
Pu-238 l-
Pu-239
Pu-240t
Pu-241
Pu-242".
Am-24lt
Am-242m:i:
Am-243 ''
Cm-242 i'
Crn-243*
Cm-244 !'
Cm-245 '(
Cm-246-i
Cm-247*
Half -life (years)
93
13
8.6
4.8
.662
1,200
.353
.315
.333
241
22.3
3,500,000
.379
1,600
5.75
21.77
1.913
7,340
77,000
32,500
72
158,000
244,000
23,420,000
2,140,000
2.85
87.8
24,390
6,540
15
387,000
433
152
7,370
446
28
17.9
8,500
4,760
15,400,000
Sourcet
1
1
1
1
1
1
3
3
2
3
1,2
1
2,3
1,2
1
1
1
1
1, 2
1
1
1
1
1
1
1
1,3,2
1, 2
1, 2
1, 2
1
1, 3
1
1
1, 3
1
1, 3
1
1
1
^'Criteria for inclusion of nuclides (1) They must have half-lives greater than 100 days. Nuclides with half-lives less than 100
days are assumed to decay to insignificance before disposal or are included in their long half-life parents. Note that this excludes
nuclides such as 1-131 with an 8.065-day half-life. (2) They shall not be naturally occurring because of their own long half-lives.
This table excludes such nuclides as K-40, Rb-87, Th-232, U-235, and U-238 with half-lives greater than 10" years. There are also
75 potentially hazardous radionuchdes that occur in research quantities that have not been included in this table.
'"Source terms 1 = Found in high-level radioactive wastes from fuel reprocessing plants, both Government and industry.
2 - Found m other nuclear power wastes such as spent fuel cladding wastes, reactor emissions, and mine and mill tailings.
3 = Found in wastes of nonnuclear power origin such as nuclear heat sources, irradiation sources, and biomedical applications.
. Indicates hazardous daughter radionuclides are present with the parent.
It is important to emphasize that although Table
10 is sufficiently accurate for planning purposes, the
indicated total national nonradioactive hazardous
waste volume of 10 million tons (9 million metric
tons) per year is not a firm number but an estimate
based on currently available information. A more
accurate indication of actual waste volumes will
become available only after a comprehensive national
waste inventory has been accomplished for specific
waste streams.
-------
Appendix C
DECISION MODEL FOR SCREENING AND SELECTING
HAZARDOUS COMPOUNDS
AND RANKING HAZARDOUS WASTES
A preliminary decision model was developed for
interim use in order ;o screen and select hazardous
compounds and rank hazardous wastes. The decision
model used for purposes of this study is not nearly as
sophisticated as that required for standard-setting
purposes. An explanation of the terminology and
definitions utilized are included.
It is essential to make a clear distinction between
development and application of criteria for purposes
of designating hazardous wastes and development and
application of a priority ranking system for hazardous
wastes despite the fact that similar or related data
must be manipulated. The distinction is that the
hazardous waste criteria relate solely to the intrinsic
hazard of the waste on uncontrolled release to the
environment regardless of quantity or pathways to
man or other critical organisms. Therefore criteria
such as toxicity, phytotoxicity, genetic activity, and
bioconcentration are utilized.
In contrast, in the development of a priority
ranking system, it is obvious that the threat to public
health and environment from a give., hazardous waste
is strongly dependent upon the quantity of the waste
involved, the extent to which present treatment
technology and regulatory activities mitigate against
the threat, and the pathways to man or other critical
organisms.
DEFINITIONS OF ABBREVIATIONS USED IN
THE SCREENING MODEL
Maximum permissible concentration (MFC)
levels: Levels of radioisotopes in waste streams which
if continuously maintained would result in maximum
permissible doses to occupationally exposed workers
and which may be regarded as indices of the
radiotoxicity of the different radionuclides.
Bioconcentration (bioaccumulat/on, biomagnifica-
tion): The process by which living organisms concen-
trate an eler. ^nt or compound to levels in excess of
those in the surrounding environment.
National Fire Protection Association (NFPA) cate-
gory 4 flammable materials: Materials including very
flammable gases, very volatile flammable liquids, and
materials that in the form of dusts or mists readily
form explosive mixtures when dispersed in air.
NFPA category 4 reactive materials: Materials
which in themselves are readily capable of detonation
or of explosive decomposition or reaction at normal
temperatures and pressures.
Lethal dose fifty (LD50). A calculated dose of a
chemical substance which is expected to kill 50
percent of a population of experimental animals
exposed through a route other than respiration. Dose
concentration is expressed in milligrams per kilogram
of body weight.
Lethal concentration fifty (LC50): A calculated
concentration which when administered by the
respiratory i jte is expected to kill 50 percent of a
population of experimental animals during an expo-
sure of 4 hours. Ambient concentration is expressed
in milligrams per liter.
Grade 8 dermal irritation: An indication of
necrosis resulting from skin irritation caused by
application of a 1-percent chemical solution.
Median threshold limit (96-hour TLm): That con-
centration of a material at which it is lethal to 50
percent of the test population over a 96-hour
55
-------
56
DISPOSAL OF HAZARDOUS WASTES
exposure period. Ambient concentration is expressed
in milligrams per liter.
Phytotoxicity: Ability to cause poisonous or
toxic reactions in plants.
Median inhibitory limit (ILm): That concentra-
tion at which a 50-percent reduction in the biomass,
cell count, or photosynthetic activity of the test
culture occurs compared to a control culture over a
14-day period. Ambient concentration is expressed in
milligrams per liter.
Genetic changes: Molecular alterations of the
deoxyribonucleic or ribonucleic acids of mitotic or
meiotic cells resulting from chemicals or electro-
magnetic or particulate radiation.
CRITERIA FOR SCREENING AND SELECTION
The screening criteria are based purely on the
inherent or intrinsic characteristics of the waste as
derived from its constituent hazardous compounds.
The problem in seeking a set of criteria becomes one
of establishing for public health and the environment
some acceptable level of tolerance. Wastes displaying
characteristics outside of these predetermined toler-
ance levels are designated as hazardous. This approach
requires that defensible thresholds be selected for
each tolerance level. For example, if the toxicity
threshold is defined as an LDSO of 5,000 milligrams
per kilogram of body weight or less, all wastes
displaying equal or lower mean lethal dose levels
would be designated hazardous. Similar numeric
threshold values were developed for other basic
physical, chemical, or biological criteria utilized in
the screening phase of the decision model. Ideally
then, the decision criteria for designating hazardous
wastes could be based upon numeric evaluations of
intrinsic toxicological, physical, and chemical data.
In addition, a criteria system for screening hazard-
ous wastes must retain a degree of flexibility. This is
self-evident because all potential wastes, let alone
their composition, cannot now be identified. Conse-
quently, it appears that a technically sound and
administratively workable criteria system must have
levels of tolerance against which any waste stream can
be compared.
As a result, a preliminary screening model was
developed as illustrated in Figure 5. Each stage of the
screening mechanism compares the characteristics of
a waste stream to some preset standard. Qualification
due to any one or more screens automatically
designates a waste as hazardous.
PRIORITY RANKING OF WASTES
There is little doubt that, on the basis of intrinsic
properties alone, many wastes will qualify as hazard-
ous wastes. Therefore it was necessary to rank these
wastes in priority fashion so that those presenting the
most imminent threats to public health and the
environment receive the greatest attention.
To assess the magnitude of the threat posed by
hazardous wastes is difficult. Such a determination
requires input concerning the inherent hazards of the
wastes, the quantities of waste produced, and the ease
with which those hazards can be eliminated or
circumvented. These considerations were incor-
porated into numerical factors, which in turn were
used to determine the priority of concern of a
particular waste. The final numerical factor is
designed to represent the volume of the environment
potentially polluted to a critical level by a given
waste. The assumption is made that all sectors of the
environment are equally valuable so that a unit
volume of soil is as important as a unit volume of
water or air. This simplification does riot reflect the
fact that atmospheric and aquatic contaminants are
more mobile than terrestrial ones but does recognize
the problem of environmental transfer from one
phase to another.
The numerical factor is derived by dividing the
volume of a waste by its lowest critical product. This
may be expressed mathematically as
where
R = ranking factor
0 = annual production quantity for the waste
being ranked
CP = critical product for the waste being
ranked
CP is the value of the lowest concentration at
which any of the hazards of concern become manifest
in a given environment multiplied by an index
representative of the waste's mobility into that
environment. Hence, for a waste that will be dis-
charged to water or to a landfill where leaching will
-------
DECISION MODEL FOR SCREENING AND SELECTING HAZARDOUS COMPOUNDS
57
WASTE
STREAM
DOES WASTE CONTAIN
RADIOACTIVE CONSTITUENTS
> MPC LEVELS?
i
NO
IS WASTE SUBJECT TO
BIOCONCENTRATION?
1
NO
IS WASTE FLAMMABILITY
IN NFPA CATEGORY 4?
1
NO
f
IS WASTE REACTIVITY
IN NFPA CATEGORY 4?
>
r NO
DOES WASTE HAVE AN ORAL
LD, „ < 50 mg/kg?
1
, NO
IS WASTE INHALATION TOXICITY
200 ppm AS GAS OR MIST'
LCSO < 2 mg/liter AS DUST?
i
NO
IS WASTE DERMAL PENETRATION
TOXICITY LDSO < 200 mg/kg?
1
, NO
IS WASTE DERMAL IRRITATION
REACTION < GRADE 8?
^
YES
YES
YES
YES
YES
YES
YES
YES
f NO
DOES WASTE HAVE AQUATIC
96 hr TLm < 1,000 mg/liter?
1
NO
IS WASTE PHYTOTOXICITY
IL, „ < 1,000 mg/liter?
i
, NO
DOES WASTE CAUSE
GENETIC CHANGES?
^
NO
OTHER WASTES
YES
YES
YES
HAZARDOUS WASTES
Figure 5. Flowchart of the hazardous waste screening model.
-------
58
DISPOSAL OF HAZARDOUS WASTES
occur, the product might be the 96-hour TLm to fish
for that waste (e.g., 1 milligram per liter) multiplied
by its solubility index (SI). SI is defined as a
dimensionless number between 1 and infinity ob-
tained by dividing 10fl milligrams per liter by the
solubility of the waste in milligrams per liter. A waste
soluble in water to 500,000 milligrams per liter has a
solubility index calculated as follows
si- 1Q6
SI - ^1
This presumes that all wastes miscible in water or
soluble to more than 1,000,000 milligrams per liter
will have similar mobility patterns and thus _hould
receive a maximum index of 1. CP for the example
waste would then be calculated as follows
CP - 96-hr TLm X SI
= 1 milligram pei liter X 2
~ 2 milligrams per liter
Similarly, for atmospheric pollutants, CP might be
LC50 multiplied by the volatility index. This index
would be derived by dividing atmospheric pressure
under ambient conditions by the vapor pressure of
the waste. Potential for suspension of dusts in air
would be given a mobility index of 1.
The aqueous and atmospheric environments are of
greatest concern since discharge to the land represents
major hazard in the form of volatilization of wastes
or leaching. Whe^e data are available on phytotoxicity
or other hazards related to direct contact with wastes
in soil, CP for ranking would be derived from use of
the critical concentration at which the hazard
becomes apparent and a mobility index of 1.
Actual waste stream data are most desirable for
use in the priority ranking formulation. However,
since such data are generally lacking, the additive
estimations recommended for interim use can be
employed for priority ranking until waste stream data
become available.
-------
Appendix D
SUMMARY OF HAZARDOUS WASTE TREATMENT
AND DISPOSAL PROCESSES
The objectives of hazardous waste treatment are
the destruction or recovery for reuse of hazardous
substances and/or the conversion of these substances
to innocuous forms that are acceptable for uncon-
trolled disposal. Several unit processes are usually
required for complete treatment of a given waste
stream. In some cases, hazardous residues that cannot
be destroyed, reused, or converted to innocuous
forms result from treatment. These residues, there-
fore, require controlled storage or disposal.
This appendix presents a description of each of the
treatment and disposal processes examined during
this study. No claim is made that these hazardous
waste treatment processes or combinations of proc-
esses and storage or disposal methods are environ-
mentally acceptable. Treatment technology can be
grouped into the following categories physical,
chemical, thermal, and biological. These processes are
all utilized to some extent by both the public and
private sectors. However, treatment processes have
had only limited application in hazardous waste
management because of economic constraints, and, in
some cases, because of technological constraints.
The physical treatment processes are utilized to
concentrate waste brines and remove soluble organics
and ammonia from aqueous wastes. Processes such as
flocculation, sedimentation, and filtration are widely
used throughout industry, and their primary function
is the separation of precipitated solids from the liquid
phase. Ammonia stripping is utilized for removing
ammonia from certain hazardous waste streams.
Carbon sorption will remove many soluble organics
from aqueous waste streams. Evaporation is utilized
to concentrate brine wastes in order to minimize the
cost of ultimate disposal.
The chemical treatment processes are also a vital
part of proper hazardous waste management
Neutralization is carried out in part by reacting acid
wastes with basic wastes. Sulfide precipitation is
required in order to remove toxic metals like arsenic,
cadmium, mercury, and antimony. Oxidation-
reduction processes are utilized in treating cyanide
and chromium-6 bearing wastes.
Thermal treatment methods are used for destroy-
ing or converting solid or liquid combustible hazard-
ous wastes. Incineration is the standard process used
throughout industry for destroying liquid and solid
wastes. Pyrolysis is a relatively new thermal process
that is used to convert hazardous wastes into more
useful products, such as fuel gases and coke.
Biological treatment processes can also be used for
biodegrading organic wastes; however, careful con-
sideration needs to be given to the limitations of
these processes. These systems can operate effectively
only within narrow ranges of flow, composition, and
concentration variations Biological systems generally
do not work on solutions containing more than 1 to 5
percent salts. Systems that provide the full range of
biodegradation facilities usually require large land
areas. Toxic substances present a constant threat to
biological cultures. In summary, biological treatment
processes should be used only when the organic waste
stream is diluted and fairly constant in its composi-
tion.
Disposal methods currently used vary depending
upon the form of the waste stream (solid or liquid),
transportation costs, local ordinances, etc. Dumps
and landfills are utilized for all types of hazardous
wastes, ocean disposal and deep-well injection are
used primarily for liquid hazardous wastes. Engi-
59
-------
60
DISPOSAL OF HAZARDOUS WASTES
neered storage or a secure landfill should be utilized
for those hazardous wastes for which no adequate
treatment processes exist.
Each of the processes evaluated by EPA is de-
scribed in this appendix in some detail. An assessment
of the waste handling capabilities is also included.
The most widely applicable processes are incinera-
tion, neutralization, and reduction.
PHYSICAL TREATMENT
Reverse osmosis: The physical transport of a
solvent across a membrane boundary, where external
pressure is applied to the side of less solvent
concentration so that the solvent will flow in the
opposite direction. This allows solvent to be ex-
tracted from a solution, so that the solution is
concentrated and the extracted solvent is relatively
pure. Almost any dissolved solid can be treated by
reverse osmosis, provided the concentrations are not
too high and it is practical to adjust the pH to range
from 3 to 8.
Dialysis: A process by which various substances in
solution having widely different molecular weights
may be separated by solute diffusion through semi-
permeable membranes. The driving force is the
difference in chemical activity of the transferred
species on the two sides of the membrane. The oldest
continuing commercial use of dialysis is in the textile
industry. Dialysis is particularly applicable when
concentrations are high and dialysis coefficients are
disparate. It is a suitable means of separation for any
materials on the hazardous material list that form
aqueous solutions.
Electrodialysis: Similar to dialysis in that dis-
solved solids are separated from their solvent by
passage through a semipermeable membrane. It
differs from dialysis in its dependence on an electric
field as the driving force for the separation. Electro-
dialysis is applicable when it is desired to separate out
a variety of ionized species from an un-ionized
solvent such as water. lonizable nitrates and phos-
phates [e.g., Pb(NO3)2, Na3PO4 | are removed with
varying degrees of efficiency. With regard to NDS's,
electrodialysis is applicable for the treatment of waste
streams for which it is desirable to reduce the
concentrations of ionizable species in the inter-
mediate range (10,000 to 500 parts per million) over
a broad range of pH (e.g., 1 to 14). If an effluent of
concentration lower than 500 parts per million is
desired, the electrodialysis effluent could be fed into
another treatment process.
Evaporation.' The removal of solvent as vapor
from a solution or slurry. This is normally accom-
plished by bringing the solvent to its boiling point to
effect rapid vaporization. Heat energy is supplied to
the solvent, and the vapor evolved must be continu-
ously removed from above the liquid phase to prevent
its accumulation. The vapor may or may not be
recovered, depending on its value. Thus, the principal
function of evaporation is the transfer of heat to the
liquid to be evaporated. Evaporation processes are
widely used throughout industry for the concentra-
tion of solutions and for the production of pure
solvents. Evaporation represents the most versatile
wastewater processing method available that is
capable of producing a high-quality effluent. It is,
however, one of the most costly processes and is
therefore generally limited to the treatment of
wastewater with high solids concentrations or to
wastewater where very high decontamination is
required (e.g., radioactive wastes).
Carbon sorption: A process in which a substance
is brought into contact with a solid and is held at the
surface or internally by physical and/or chemical
forces. The solid is called the sorbent and the sorbed
substance is called the sorbate. The amount of
sorbate held by a given quantity of sorbent depends
upon several factors, including the surface area per
unit volume (or weight) of the sorbent and the
intensity of the attractive forces. Activated carbon
has been historically used to remove organic and
other contaminants from water. Activated carbon
sorption has been used to remove dissolved refractory
organics from municipal waste streams and to clean
up industrial waste streams. It has been used to
remove some heavy metals and other inorganics from
water. Carbon sorption can remove most types of
organic wastes from water. Those that have low
removal by carbon include short carbon chain polar
substances such as methanol, formic acid, and
perhaps acetone. This process is being utilized to treat
herbicide plant wastes. Also, full-scale carbon sorp-
tion units have been successfully used for petroleum
and petrochemical wastes.
-------
SUMMARY OF HAZARDOUS WASTE TREATMENT AND DISPOSAL PROCESSES
61
Ammonia stripping: The removal of ammonia
from alkaline aqueous wastes by stripping with steam
at atmospheric pressure. The waste stream, at or near
its boiling point, is introduced at the top of a packed
or bubble cap tray-type column and contacted
concurrently with steam. Ammonia, because of its
high partial pressure over alkaline solutions, is readily
condensed and reclaimed for sale, and liquid effluents
from a properly designed steam stripping column will
be essentially ammonia free. This process is quite
useful in the treatment of ammonia-bearing wastes.
However, it can also be used to remove various
volatile and organic contaminants from waste
streams.
Filtration: The physical removal of the solid
constituents from the aqueous waste stream by means
of a filter medium. A slurry is forced against the filter
medium. The pores of the medium are small enough
to prevent the passage of some of the solid particles;
others impinge on the fiber of the medium. Conse-
quently, a cake builds up on the filter, and after the
initial deposition, the cake itself serves as the barrier.
The capacity of this process is governed by the flow
rate of the fluid filtrate through the bed formed by
the solid particles. Most of the aqueous hazardous
waste streams which contain solid constituents will be
treated by this process.
Sedimentation (settling): A process used to
separate aqueous waste streams from the particles
suspended in them. The suspension is placed in a
tank, and the particles are allowed to settle out; the
fluid can then be removed from above the solid bed.
The final state is that of a packed bed resembling a
filter cake if the process is allowed to continue long
enough. Sedimentation is widely used throughout
industry for treatment of waste streams for which
there is a need for separation of precipitated solids
from the liquid phase.
Flocculation: A process used when fine particles
in a waste stream are difficult to separate from the
medium in which they are suspended. These waste
constituents are in the low and fractional micrometer
range of sizes; they settle too slowly for economic
sedimentation and are often difficult to filter. Thus,
this process is applied to gather these particles
together as flocculates, which allows them to settle
much faster. The .resulting sediment is less dense and
is often mobile. The particles also filter more readily
into a cake which is permeable and does not clog.
Like sedimentation, flocculation is widely used
throughout industry for treatment of waste streams
for which there is a need for separation of precipi-
tated solids from the liquid phase.
CHEMICAL TREATMENT
Jon exchange: The reversible interchange of ions
between a solid and a liquid phase in which there is
no permanent change in the structure of the solid. It
is a method of collecting and concentrating undesir-
able materials from waste streams. The mechanism of
ion exchange is chemical, utilizing resins that react
with either cations or anions. Ion exchange tech-
nology has been available and has been employed for
many years for removing objectionable traces of
metals and even cyanides from the various waste
streams of the metal process industries. Objectionable
levels of fluorides, nitrates, and manganese have also
been removed from drinking water sources by means
of ion exchange. Technology has been developed to
the extent that the contaminants that are removed
can be recycled, readily transformed into a harmless
state, or safely disposed of.
Neutralization: A process utilized to prevent
excessively acid or alkaline wastes from being dis-
charged in plant effluents. Some of the methods used
to neutralize such wastes are (1) mixing wastes such
that the net effect is a near-neutral pH, (2) passing
acid wastes through beds of limestone, (3) mixing
acid with lime slurries, (4) adding proper proportions
of concentrated solutions of caustic soda (NaOH) or
soda ash to acid wastewaters, (5) blowing waste
boiler-flue gas through alkaline wastes, (6) adding
compressed CO2 to alkaline wastes, (7) adding
sulfuric acid to alkaline wastes. Neutralization is
utilized in the precipitation of heavy metal
hydroxides or hydrous oxides and calcium sulfate.
Oxidation: A process by which waste streams
containing reductants are converted to a less hazard-
ous state. Oxidation may be achieved with chlorine,
hypochlorites, ozone, peroxide, and other common
oxidizing agents. The method most commonly
applied on a large scale is oxidation by chlorine.
Oxidation is used in the treating of cyanides and
othsr reductants.
-------
62
DISPOSAL OF HAZARDOUS WASTED
Reduction: A process whereby streams containing
oxidants are treated with sulfur dioxide to reduce the
oxidants to less noxious materials. Other reductants
that can be used are sulfite salts and ferrous sulfate,
depending on the availability and cost of these
materials. Reduction is used to treat chromium-6 and
other oxidants.
Precipitation- A process of separating solid con-
stituents from an aqueous waste stream by chemical
changes In this process, the waste stream is converted
from one with soluble constituents to one with
insol ble constituents. This process is applicable to
the treatment of waste streams containing heavy
metals.
Calcination' The process of heating a waste
material to a high temperature without fusing in
order to effect useful changes, such as oxidation or
pulverization. Calcination is commonly applied in the
processing of high-level radioactive wastes.
THERMAL TREATMENT
Incineration' A controlled process to convert a
waste to a less bulky, less toxic, or less noxious
material. Most incineration systems contain four basic
components: a waste storage facility, a burner and
combustion chamber, an effluent purification device
when warranted, and a vent or a stack. The 11 basic
types of incineration units are open pit, open
burning, multiple chamber, multiple hearth, rotary
kiln, fluidized bed, liquid combustors, catalytic
combustors, afterburners, gas combustors, and stack
flares. The type of waste for which each of these
incineration units is best suited is detailed diagram-
matically in Figure 6.
Pyrolysis: The thermal decomposition of a com-
pound Wastes are subjected to temperatures of about
1200 F ± 300 F (650 C + 150 C), depending upon the
nature of the wastes, in an essentially oxygen-free
atmosphere. Without oxygen, the wastes cannot burn
and are broken down (pyrolyzed) into steam, carbon
oxides, volatile vapors, and charcoal. Most municipal
and industrial wastes that are basically organic in
nature can be converted to coke or activated charcoal
and gaseous mixtures which may approach natural gas
in heating values through the utilization of pyrolysis.
BIOLOGICAL TREATMENT
Activated sludge: A process in which biologically
active growths are continuously circulated and con-
tacted with organic waste in the presence of oxygen.
Normally, oxygen is supplied to the system in the
form of fine air bubbles under turbulent conditions.
The activated sludge is composed of the biologically
active growths and contains micro-organisms that
feed on the organic waste. Oxygen is required to
sustain the growth of the micro-organisms. In the
conventional activated sludge process, incoming
wastewater is mixed with recycled activated sludge
and the mixture is aerated for several hours in an
aeration tank. During this period, adsorption, floccu-
lation, and various oxidation reactions take place
which are responsible for removing much of the
organic matter from the wastewater. The effluent
from the aeration tank is passed to a sedimentation
tank where the flocculated micro-organisms or sludge
settles out. A portion of this sludge is recycled as seed
to the influent wastewater. The activated sludge
process has been applied very extensively in the
treatment of refinery, petrochemical, and biode-
gradable organic wastewaters.
Aerated lagoon: The use of a basin of significant
depth | usually 6 to 17 feet (1.83 to 5.19 meters) | in
which organic waste stabilization is accomplished by
a dispersed biological growth system and where
oxygenation is provided by mechanical or diffused
aeration equipment. Aerated lagoons have been used
successfully as an economical means to treat indus-
trial wastes where high-quality effluents are not
required.
Trickling filter' The use of artificial beds of rocks
or other porous media through which the liquid from
settled organic waste is percolated. In the process, the
waste is brought into contact with air and biological
growths. Settled liquid is applied intermittently or
continuously over the top surface of the filter by
means of a distributor. The filtered liquid is collected
and discharged at the bottom. The primary removal
of organic material is not accomplished through
filtering or straining action. Removal is the result of
an adsorption process similar to activated sludge
which occurs at the surfaces of the biological growths
or slimes covering the filter media. Trickling filters
have been used extensively in the treatment of such
industrial wastes as acetaldehyde, acetic acid,
acetone, acrolem, alcohols, benzene, butadiene,
chlorinated hydrocarbons, cyanides, epichJorohydrin,
formaldehyde, formic acid, ketones, monoethanol-
-------
SUMMARY OF HAZARDOUS W/^TE TREATMENT AND DISPOSAL PROCESSES
63
SOLIDS
LIQUIDS
GASES
OPEN PIT
OPEN
INCINERATION
MULTIPLE.
CHAMBER
MULTIPLE
HEARTH
ROTARY KILN
FLUIDI?ED BED
LIQUID
COMBUSTORS
CATALYTIC
COMBUSTORS
AFTERBURNERS
GAS
COMBUSTORS
STACK
FLARES
Figure 6. Types of incinerators and their applications.
amines, phenolics, propylenedichloride, terpenes,
ammonia, ammonium nitrate, nylon and nylon
chemical intermediates, resins, and rocket fuels.
Waste stabilization ponds: The use of large
shallow basins (usually 2 to 4 feet (0.61 to 1.^2
meters) deep | for the purpose of purifying waste-
water by storage under climatic conditions that favor
the growth of algae. The conversion of organics to
inorganics, or stabilization, in such ponds rasults from
the combined metabolic activity of bacte 'a, algae,
and surface aeration, 'aste stabilization ponds have
been widely used where land is plentiful and climatic
conditions are favorable. They have been used exten-
sively in treating industrial wastewaters when a high
degree of purification is not required. More recently,
stabilization ponds have proven to be successful in
treating steel mill wastes.
ULTIMATE DISPOSAL
Landfill disposal. A well-controlled and sanitary
method of disposal of wastes upon land. Common
landfill disposal methods are (1) mixing with soil. (2)
shallow burial, (3) combinations of these. The utiliza-
tion of landfill procedures for the disposal of certain
hazardous waste materials at an NDS, in an industrial
environment, or in municipal applications will un
doubtedly be required in the future
Deep-well disposal. A system of disposing of raw
-------
64
DISPOSAL OF HAZARDOUS WASTES
or treated filtered hazardous waste by pumping it
into deep wells where it is contained in the pores of
permeable subsurface rock separated from other
groundwater supplies by impermeable layers of rock
or clay. Subsurface injection has been extensively
used in the disposal of oil field brines (between
10,000 and 40,000 brine injection wells in the United
States). The number of industrial waste injection
wells in the United States has increased to more than
100. Injection wells can be used by virtually any type
of industry that is located in a proper geologic
environment and that has a waste product amenable
to this method. Some industries presently using this
method are chemical and pharmaceutical plants,
refineries, steel and metal industries, paper mills, and
coke plants.
Land burial disposal: A method adaptable to
those hazardous materials that require permanent
disposal. Disposal is accomplished by either near-
surface or deep burial. In near-surface burial, the
material is deposited either directly into the ground
or is deposited in stainless steel tanks or concrete-
lined pits beneath the ground. In land burial, the
waste is transported to a selected site where it is
prepared for final burial. At the present time,
near-surface burial of both radioactive and chemical
wastes is being conducted at several AEC and
commercially operated burial sites. Pilot plant studies
have been conducted for deep burial in salt forma-
tions and hard bedrock. Land burial is a possible
choice for the hazardous materials that require
complete containment and permanent disposal. This
includes radioactive wastes as well as highly toxic
chemical wastes. At the present time, only near-
surface burial is used for the disposal of most wastes.
Ocean dumping. The process of utilizing th
ocean as the ultimate disposal sink for all types of
waste materials (including hazardous wastes). There
are three basic techniques for ocean disposal of
hazardous wastes. One technique is bulk disposal for
liquid or slurry-type wastes. Another technique is
stripping obsolete or surplus World War II cargo ships,
loading the ships with obsolete munitions, towing
them out to sea, and scuttling them at some
designated spot. The third technique is the sinking at
sea of containerized hazardous toxic wastes. The
broad classes of hazardous wastes dumped at sea have
been categorized as follows' industrial wastes;
obsolete, surplus, and nonserviceable conventional
explosive ordinance; chemical warfare wastes; and
miscellaneous hazardous wastes.
Engineered storage' A potential system to be
utilized for those hazardous wastes (especially radio-
active) for which no adequate disposal methods exist.
An engineered storage facility would have applica-
bility until such time as a method for permanent
disposal of these wastes is developed. A near-ground-
surface engineered storage facility must provide safe
storage of the solidified hazardous wastes for long
periods of time and retrievability of the wastes at any
time during this storage. The ultimate goal is to
transfer these wastes to a permanent disposal site
when a suitable site is found. This process is being
proposed for the long-term storage of high-level
radioactive wastes, some low-level radioactive wastes
will probably also go into engineered storage
facilities.
Detonation: A process of exploding a quantity of
waste with sudden violence. Detonation can be
performed by several means which include thermal
shock, mechanical shock, electrostatic charge, or
contact with incompatible materials. Detonation of a
single waste may be followed by secondary explo-
sions or fire. Detonation is most commonly applied
to explosive waste materials. However, several flam-
mable waste streams can also be detonated.
-------
Appendix E
DECISION MAPS FOR ON-SITE VERSUS
OFF-SITE TREATMENT AND DISPOSAL
When a hazardous waste generator elects to treat
or dispose of his hazardous waste in an environ-
mentally acceptable manner, he must make the
important economic decision as to whether a particu-
lar waste stream should be processed on site or off
site at some regional treatment facility. In order to
make a sound business decision between these
options, an industrial manager must consider a
number of variables such as the following: the
chemical composition of the particular waste stream,
the on-site availability and unit cost of a satisfactory
treatment process, the quantity of the waste stream,
and the distance to and user charge of the nearest
off-site processing facility.
To provide a general insight into the economics of
this problem, information was compiled on eight
commonly occurring industrial hazardous waste
stream types, and a mathematical model was formu-
lated. The mathematical model resulted in economic
decision maps for each of the eight industrial waste
categories (Figures 7 through 15). (Nine decision
maps appear because two maps are included for heavy
metal sludges.)
As a result of this analysis, it was concluded that
economic considerations favor the off-site treatment
and disposal of seven out of the eight waste stream
types examined. Only in the case of dilute aqueous
heavy metals (Figure 15) is the strategy of on-site
treatment more economical.
The decision map for concentrated heavy metals
(Figure 7) is typical. The following discussion will
identify and interpret, point by point, those aspects
of the map that are considered significant.
Point A on the map represents data collected for a
sample of actual waste sources. This point is defined
by the mean separation between sources (the average
distance between some waste sources actually found
within a particular region) and the mean source size
(size as measured by waste stream volume). The
position of Point A on the map shows whether the
on-site or off-site treatment alternative is economi-
cally preferable. Here, Point A lies comfortably
within the "off-site" region of the map; therefore,
off-site treatment of wastes collected from multiple
sources is the most logical choice.
The vertical lines corresponding to the smallest
and largest sources in the sample are also shown for
perspective. For each of the stream types, an attempt
was made to include the largest single producer of the
waste in the country.
Two other points on the map are of interest. Point
B defines the separation between sources that would
be required if on-site processing is to be feasible,
assuming no change in the sample mean. For concen-
trated heavy metals, this change-of-strategy separa-
tion distance is 360 miles (580 kilometers) compared
to the mean value of 81 miles (131 kilometers).
Point C defines the source size at which on-site
processing becomes feasible for sources separated by
the sample mean separation. For concentrated heavy
metals, this size is 16 million gallons (61 million
liters) per year, compared to the sample mean of
325,000 gallons (1 2 million liters) per year and a
sample maximum of 950,000 gallons (3.6 million
liters) per year. Clearly, off-site processing is prefera-
ble for concentrated heavy metal wastes. A mean
volume concentrated heavy metal waste producer
would have to be nearly 400 miles (640 kilometers)
from any other similar waste producer before on-site
treatment would become attractive.
An examination of the succeeding eight decision
maps (Figures 8 through 15) makes it apparent that
65
-------
66
DISPOSAL OF HAZARDOUS WASTES
378,500
SOURCE SIZE (liters/yr)
3,785,000
37,850,000
378,500,000
1,610
10,000
100,000 1,000,000 10,000,000
SOURCE SIZE (gal/yr)
Figure 7, Concentrated heavy metals.
1.6
100,000,000
37,850
1,000
378,500
SOURCE SIZE (liters/yr)
3,785,000 37,850,000
378,500,000
3,785,000,000
1,610
- 161
u
cc
D
o
s
z
o
16.1 c
CO
z
10,000
100,000 1,000,000 10,000,000
SOURCE SIZE (gal/yr)
Figure 8. Dilute metals with organic contamination.
100,000,000
1,000,000,000
-------
DECISION MAPS FOR ON-SITE VERSUS OFF-SITE TREATMENT AND DISPOSAL
67
SOURCE SIZE (liters/yr)
378,500 3,785,000 37,850,000
T
378,500,000
1,610
1,000
10,000
100,000 1,000,000 10,000,000
SOURCE SIZE (gal/yr)
Figure 9. Asphalt encapsulation of heavy metal sludges.
100,000,000
3,785
1,000
37,850
SOURCE SIZE (hters/yr)
378,500 3,785,000
37,850,000
378,500,000
~~ 1,610
o
cc
o
v>
2
2
O
H
- 16 1
1,000
10,000 100,000 1,000,000
SOURCE SIZE (gal/yr)
10,000,000
1 6
100,000,000
Figure 10. Cement encapsulation of heavy metal sludges.
-------
68
DISPOSAL OF HAZARDOUS WASTES
3,785
37,850
1,000
SOURCE SIZE (llters/yr)
378,500 3,785,000
37,850,000
378,500,000
1,610
- 161
CO
UJ
O
K
z
UJ
uj
h
ui
m
Z
o
- 16.1
Q.
UJ
CO
UJ
5
1,000
10,000
100,000 1,000,000
SOURCE SIZE (gal/yr)
Figure 11. Concentrated cyanides.
10,000,000
100,000,000
10,000,
3,785
37,850
SOURCE SIZE (llters/yr)
378,500 3,785,000
37,850,000
378,500,000
16,100
1,000
10,000
100,000 1,000,000
SOURCE SIZE (gal/yr)
10,000,000
16.1
100,000,000
Figure 12. Liquid chlorinated hydrocarbons.
-------
DECISION MAPS FOR ON-SITE VERSUS OFF-SITE TREATMENT AND DISPOSAL
69
1,000
3,785
37,850
SOURCE SIZE (liters/yr)
378,500
3,785,000
V)
in
o
DC
z
LU
LU
5
LU
CD
Z
g
o.
LU
100
10
1
37,850,000
1,610
ON-SITE
TREATMENT
MEAN SOURCE
SMALLEST SOURCE
J
I
OFF-SITE
TREATMENT
LARGEST SOURCE
161
16.1
1,000
10,000 100,000
SOURCE SIZE (gal/yr)
Figure 13. Dilute cyanides.
1,000,000
1.6
10,000,000
(fi
LU
O
IT
3
0
en
Z
LU
LU
h
LU
CD
Z
O
0.
ui
W
LU
37,850
378,500
SOURCE SIZE (liters/yr)
3,785,000 37,850,000
378,500,000
10,000 P
3,785,000,000
•'.'.':; -.116,100
SMALLEST SOURCE
AT 1,000 gal/yr
10
10,000
100,000
1,000,000 10,000,000
SOURCE SIZE (gal/yr)
100,000,000
16.1
1,000,000,000
Figure 14. Chlorinated hydrocarbon and heavy metal slurries.
-------
70
DISPOSAL OF HAZARDOUS WASTES
3,785
37,850
1,000
SOURCE SIZE (liters/yr)
378,500 3,785,000
37,850,000
378,500,1
UJ
o
tc
D
O
z
LLJ
UJ
5
H
LU
co
z
o
Q-
LU
UJ
5
100 —
1,000
10,000
100,000 1,000,000
SOURCE SIZE (gal/yr)
Figure 15. Dilute heavy metals.
10,000,000
1.6
100,000,000
each is different because each particular waste stream
has its own cost characteristics as a result of different
treatment and/or disposal requirements. Only in the
case of dilute heavy metals (Figure 15) is the
above-defined Point A within the "on-site" region of
the map. Accordingly, the average generator of dilute
heavy metal wastes would logically choose on-site
treatment. Development of the model on which the
decision maps are based was made in an earlier
study.31 Included among other important results of
that particular study are discussions of location and
spacing of regional treatment facilities.
-------
Appendix F
SUMMARY OF THE HAZARDOUS WASTE
NATIONAL DISPOSAL SITE CONCEPT
In the course of investigating the NDS concept for
hazardous wastes as mandated by Section 212 of the
Solid Waste Disposal Act (P.L. 89-272, amended by
P.L. 91-512), important and relevant information was
developed. Appendixes B and D, respectively, provide
a list of hazardous wastes subject to treatment at such
sites and summaries of current methods of treatment
and disposal. This appendix summarizes the findings
related to site selection, methods and processes that
are likely to be used at a typical site, and costs for
developing and maintaining such sites. An earlier
study contains the detailed analyses performed and
the rationale for this information.1
SITING OF HAZARDOUS WASTE TREATMENT
AND DISPOSAL FACILITIES
The general approach to the site selection process
was to first regionalize the conterminous United
States into 41 multicounty regions (spheres of
influence for major industrial waste production areas,
which are closely related to hazardous waste produc-
tion areas, served as the basis for regional delinea-
tion):
(1) Seattle, Tacoma, Everett, and Bellingham,
Washington
(2) Portland, Oregon; Vancouver and Longview,
Washington
(3) San Francisco Bay Area, California
(4) Ventura, Los Angeles, and Long Beach,
California
(5) San Diego, California
(6) Phoenix, Arizona
(7) Salt Lake and Ogden, Utah
(8) Idaho Falls and Pocatello, Idaho
(9) Denver, Colorado
(10) Santa Fe and Albuquerque, New Mexico
("1) El Paso, Texas
(12) Fort Worth, Dallas, and Waco, Texas
(13) Austin, San Antonio, and Corpus Christi,
Texas
(14) Houston, Beaumont, Port Arthur, Texas
City, and Galveston, Texas
(15) Oklahoma City, Tulsa, and Bartlesville,
Oklahoma
(16) Wichita, Topeka, and Kansas City, Kansas
(17) Omaha and Lincoln, Nebraska, Des Moines,
Iowa
(18) Minneapolis, St. Paul, and Duluth, Minnesota
(19) Cedar Rapids, Michigan; Burlington and
Dubuque, Iowa;Peoria, Illinois
(20) St. Louis, Missouri; Springfield, Illinois
(21) Memphis, Tennessee
(22) Shreveport, Baton Rouge, and New Orleans,
Louisiana; Jackson, Mississippi
(23) Mobile and Montgomery, Alabama; Talla-
hassee, Florida, Biloxi and Gulf port, Mississippi;
Columbus, Georgia
(24) Huntsville and Birmingham, Alabama,
Atlanta and Macon, Georgia; Chattanooga and Nash-
ville, Tennessee
(25) Louisville, Frankfort, and Lexington, Ken-
tucky; Evansville, Indiana
(26) Albany, Troy, and Schenectady, New York
(27) Indianapolis, Indiana; Cincinnati and Day-
ton, Ohio
(28) Chicago and Kankakee, Illinois; Gary, South
Bend, Hammond, and Fort Wayne, Indiana
(29) Midland, Saginaw, Grand Rapids, Detroit,
Dearborn, and Flint, Michigan, Toledo, Ohio
(30) Columbus, Cleveland, Youngstown, and
Akron, Ohio
71
-------
72
DISPOSAL OF HAZARDOUS WASTES
(31) Pittsburgh, Johnstown, and Erie, Pennsyl-
vania
(32) Charleston, West Virginia; Portsmouth and
Norfolk, Virginia
(33) Charleston, South Carolina; Savannah and
Augusta, Georgia
(34) Winston-Salem, Raleigh, Greensboro, and
Charlotte, North Carolina
(35) Baltimore, Maryland
(36) Philadelphia, Allentown, and Harrisburg,
Pennsylvania, Camden and Elizabeth, New Jersey;
Wilmington, Delaware
(37) New York, New York, Newark and Paterson,
New Jersey
(38) Buffalo, Rochester, Syracuse, and Water-
town, New York
(39) Boston, Massachusetts
(40) Orlando, Tampa, and Miami, Florida
(41) Little Rock, Pine Bluff, and Hot Springs,
Arkansas
Thirty-six waste treatment regions were identified,
based upon the distance from the 41 major industrial
waste production centers. These are shown in Figure
16. Distances of about 200 miles (322 kilometers) in
the East and 250 miles (402 kilometers) in the West
were selected as the maximum distances any treat-
ment site should be from the industrial waste
production centers in a given subregion. Some of the
regions do not contain an industrial waste production
center; however, their boundaries are defined by
surrounding regions containing waste production cen-
ters. No region was generally permitted to cross any
major physiographic barrier. Notably, the regions are
smaller in the East than in the West.
Criteria for site selection were defined. The major
emphasis was placed on health and safety and
environmental considerations. It was recognized early
that two general types of sites would need to be
identified: waste processing plant sites and long-term
hazardous waste disposal and storage sites. Site
selection criteria and numerical weightings are pre-
sented in Table 12.
Based on the site selection criteria, a ranking,
screening, and weighting procedure was developed
and applied to all counties located in the 36 regions
which cover the country. The county-size areal unit
appeared to be of manageable size for the survey. The
output lising of all 3,050 counties in the conter-
minous United States, grouped by regional ratings, is
too voluminous for inclusion here.1 This listing
allows for the orderly and rational selection of
counties within each region, for site-specific recon-
naissance, and for later detailed field studies that
would be required in order to prove out the feasibil-
ity of a candidate site. From the total list that rates
and ranks all counties, 74 appear to be potentially the
best areas for locating hazardous waste treatment and
disposal sites. These are presented as follows by
State:
State:
Alabama
Arizona
California
Colorado
Connecticut
Florida
Georgia
Iowa
Illinois
Indiana
Kansas
Kentucky
Maryland
Massachusetts
Michigan
Mississippi
Missouri
Montana
Nebraska
Nevada
New Jersey
County
Sumter*
Dallas
Yuma
Fresno
Inyo
Kern*
Ventura
Weld
Hartford
Alachua
Dooley*
Howard
Jasper
Livingston*
Ogle
Vermilion
Jackson
Ellsworth
Franklin
Carroll
Franklin*
Worcester
Isabella*
Shiawassee
Lincoln
Audrain
Custer
Kearney
Nye*
Pershing
Washoe
Sussex
*Potential site for large-size processing facility.
-------
SUMMARY OF THE HAZARDOUS WASTE NATIONAL DISPOSAL SITE CONCEPT
73
G
o
•&
£
§
-------
74
DISPOSAL OF HAZARDOUS WASTES
TABLE 12
SITE SELECTION CRITERIA
General criteria
Weighting
Earth sciences (geology, hydrology, soils,
climatology)
Transportation (risk, economics)
Ecology (terrestrial life, aquatic hfe, birds and
wildfowl)
Human environment and resources utilization
(demography, resource utilization, public
acceptance)
Total
New Mexico
New York
North Dakota
Ohio
Oklahoma
Oregon
Pennsylvania
South Carolina
Tennessee
Texas
Utah
Eddy
Quay
San Juan
Albany
Onondaga
Otsego
Steuben
Wyoming
Grand Forks
Carro'l
Darke
Wayne
Atoka
Custer
Kay
Deschutes
Clinton
Montgomery
York*
Barnwell
Greenwood
Gibson
Montgomery
Bell
Erath*
Gillespie
Grimes
Harris*
Haskell
Kendall
Polk
Sutton
Tooele
31
28
18
23
100
Virginia
Washington
West Virginia
Wyoming
Brunswick
Caroline
Fluvana
Pittsylvania
Benton
Lincoln
Doddridge
Campbell
Laram-'e
In addition, the following are the existing or potential
Federal and State hazardous -waste treatment and
disposal sites:
Existing sites operated by AEC:
Fernald, Butler/Hamilton Counties, Ohio
Hanford Works, Benton County, Washington
Los Alamos Scientific Laboratory, Los
Alamos County, New Mexico
National Reactor Testing Station, Bingham
County, Idaho
Nevada Test Site, Nye County, Nevada
Oak Ridge, Anderson County, Tennessee
Pantex Plant, Randall County, Texas
Rocky Flats Plant, Jefferson County,
Colorado
Savannah River Plant, Aiken County, South
Carolina
Existing sites operated by DOD:
Anniston Army Depot, Alabama
Edgewood Arsenal, Maryland
Lexington Bluegrass Army Depot, Kentucky
Newport Army Ammunition Plant, Indiana
Pine Bluff Arsenal, Arkansas
Pueblo Army Depot, Colorado
Rocky Mountain Arsenal, Colorado
Tooele Army Depot, Utah
Umatilla Army Depot, Oregon
State-licensed radioactive waste sites.*
Barnwell, South Carolina
Beatty, Nevada
Hanforr' Works, Washington
Morehtjd, Kentucky
West Valley, New York
^Potential site for large-size processing facility.
*The Sheffield, Illinois, site is directly licensed through
AEC but is not operated by AEC.
-------
SUMMARY OF THE HAZARDOUS WASTE NATIONAL DISPOSAL SITE CONCEPT
75
Data on the Beatty, Nevada; Hanford, Washington;
and Morehead, Kentucky, sites are presented in
Tables 13 to 15
It should be noted that the suitability of a
particular candidate site can only be determined by
additional field studies, field testing, and technical
analyses of the data.
HAZARDOUS WASTE MANAGEMENT METHODS
AND COSTS
The approach used in this phase of the study
involved development of a model facility capable of
processing a wide variety of hazardous wastes (ex-
cluding radioactive wastes or chemical warfare agents
generated or stored at AEC or DOD installations).
Conceptual design and cost estimates were prepared
for a complete waste management system to process
and dispose of the wastes. In addition to treatment
and disposal, peripheral functions such as transporta-
tion, storage, and environmental monitoring were also
considered.
The basic objective of waste treatment at a
hazardous waste processing facility is the conversion
of hazardous substances to forms that are acceptable
for disposal or reuse. Since the majority of hazardous
waste streams are complex mixtures containing
several chemical species, treatment for removal
and/or conversion of certain nonhazardous substances
from the waste stream will also be required in order
to comply with pollution control regulations. In a
number of instances, treatment for the nonhazardous
substances will dictate the type of process used and
will entail the most significant operational costs (e.g.,
acid neutralization).
Broad treatment capability in a central processing
facility will permit the processing of many non-
hazardous wastes which could give the facility the
advantage of economy of scale. In order to maintain a
competitive position in the waste processing field in
the case of a privately operated facility, it is
anticipated that all wastes which can be processed
with some return on investment will be accepted. It is
possible that the volume of nonhazardous wastes will
exceed the volume of hazardous wastes, perhaps by
wide margins, in many areas. Inclusion of non-
TABLE 13
REPRESENTATIVE COMMERCIAL RADIOACTIVE WASTE BURIAL SITE CHARACTERISTICS
BEATTY, NEVADA, SITE
Ownership
Population density in area
Distance from nearest town
Area-
Site
Controlled land
Communications
Precipitation
Drainage
Bedrock
Depth
Type
Surficial material:
Depth
Type
Groundwater'
Depth
Slope
Land and water use downstream
General soil characteristics
Monitoring instruments and devices
Trenches
Dimensions
Design
Waste handling
Transportation
Machinery
Processing
Burial
State of Nevada, leased to the Nuclear Engineering Company, Inc.
Virtually uninhabited
About 12 miles (19 kilometers) southeast of Beatty
80 acres (32 hectares)
No land controlled—desert
Good; U.S. highway 95
2.5-5.0 inches (6.35-12.7 centimeters) per year
Adequate
Estimated to be 575+ feet (175+ meters)
Sedimentary and metamorphic
575 feet (175 meters)
Alluvial clay, sand, etc.
275-300 feet (84-92 meters)
Southeast, approximately 30 feet pel mile (5.67 meters per kilometer)
Very little, desert conditions
Semiarid desert; deep soil
14 survey instruments, film, air monitors, etc
650 by 50 by 20 feet (198 by 15.2 by 6.1 meters)
Standard, drain to sump; 4-foot (1 2-meter) backfill, no watei collected
By company
Tank truck, trailer trucks, bulldozer, 35-ton crane
Liquids solidified
Special nuclear materials spaced at bottom, slit trench for high-activity materials
-------
76
DISPOSAL OF HAZARDOUS WASTES
TABLE 14
REPRESENTATIVE COMMERCIAL RADIOACTIVE WASTE BURIAL SITE CHARACTERISTICS:
HANFORD, WASHINGTON, SITE
Ownership
Population density in area
Distance from nearest town
Area:
Site
Controlled land
Communications
Precipitation
Drainage
Bedrock:
Depth
Type
Surficial material:
Depth
Type
Groundwater.
Depth
Slope
Land and water use downstream
General soil characteristics
Monitoring instruments and devices
Trenches:
Dimensions
Design
Waste handling:
Transportation
Machinery
Processing
Burial
State of Washington, leased to the Nuclear Engineering Company, Inc.
No resident population
25 miles (40 meters) north of Richland
100 acres (40 hectares)
1,000 acres (405 hectares) State owned
Good; AEC Hanford reservation
6-8 inches (15-20 centimeters) per year
Well drained
Estimated to be 250-450 feet (76-137 meters)
Basalt
150-350 feet (47-107 meters)
Silty sand, gravel, clay
240 feet (73 meters)
North and east, approximately 15-35 feet per mile (2.8-6.6 meters per kilometer)
Columbia River—all uses
Little precipitation; deep, dry soil
Survey instruments, film, counters
300 by 60 by 25 feet (92 by 18 by 7.6 meters)
Standard; no water collects in sump
By company
Crane, shovel, bulldozer, forklifts, etc.
Liquids solidified
Special nuclear materials spaced; separate trench for ion-exchange resins
hazardous waste processing also increases the oppor-
tunities for resource recovery (e.g., recovery of
metals, oils, and solvents).
It must be emphasized that the model facility
developed in this study was primarily designed for
processing hazardous wastes. Therefore, processing
facilities designed for both hazardous wastes and
nonhazardous wastes may be different in many
respects. A number of factors will dictate individual
design variations for a given facility. Foremost will be
the volumes and types of wastes, both hazardous and
nonhazardous, that will be received for processing.
One facility may require many different processes
whereas another may require only one. Furthermore,
processes selected for the model facility are not
intended to be all inclusive. A wide variety of
processes, in addition to those selected for the model
facility, is available to meet the needs of a particular
location.
DESCRIPTION OF MODEL FACILITIES
Hazardous Waste Processing Facility
The model hazardous waste processing facility
incorporates the various functions related to waste
treatment and disposal at one central location. The
facility is basically a chemical processing plant that
has design features for safe operation in a normal
industrial area. Effluents discharged from the facility
will be limited to those that meet applicable water
and air standards. Local solid waste disposal will be
limited to nonhazardous wastes that are acceptable
for burial at a conventional landfill. The conventional
landfill may be located adjacent to the processing
facility or a short distance away. In general, non-
hazardous waste brines resulting from hazardous
waste treatment will be disposed of by ocean dump-
ing where appropriate to avoid potential quality
impairment of fresh water sources. Land disposal of
-------
SUMMARY OF THE HAZARDOUS WASTE NATIONAL DISPOSAL SITE CONCEPT
77
TABLE 15
REPRESENTATIVE COMMERCIAL RADIOACTIVE WASTE BURIAL SITE CHARACTERISTICS:
MOREHEAD, KENTUCKY, SITE
Ownership
Population density in area
Distance from nearest town
Area:
Site
Controlled land
Communications
Precipitation
Drainage
Bedrock:
Depth
Type
Surficial material:
Depth
Type
Ground water:
Depth
Slope
Land and water use downstream
General soil characteristics
Monitoring instruments and devices
Trenches.
Dimensions
Design
Waste handling:
Transportation
Machinery
Processing
Burial
State of Kentucky, leased to the Nuclear Engineering Company, Inc.
Sparse (rural—Maxey Flats)
10 miles (16 kilometers) northwest of Morehead
200 acres (81 hectares)
1,000 acres (405 hectares)
Fair; State highway runs north and south
46 inches (117 centimeters) per year (heavy storms)
Well drained
Estimated to be 50-75 feet (15-23 meters)
Shale, sandstone, siltstone
Estimated to be 50-75 feet (15-23 meters)
Shale, clay, siltstone
35-50 feet (11-15 meters) ["perched" 2-6 feet (0.61-1.83 meters)!
Erratic
Very little nearby; no data exist at great distances
Very impermeable; good soil sorption
14 survey instruments, film, air monitors, etc.
300 by 50 by 20 feet (92 by 15 by 6.1 meters)
Standard, sump; water is pumped
By company
Crane, bulldozer, forklifts, etc.
Liquids solidified
Performed according to the Radiation Safety PJan developed by the Nuclear Engineering
Company, Inc.
these brines is a potential alternative method that is
less desirable and that will be used only in arid
regions, and even there infrequently. All such disposal
operations will be in accordance with applicable local,
State, and Federal standards.
In order to accomplish treatment and disposal
objectives, the facility will also contain equipment
and structures necessary for transporting, receiving,
and storing both wastes and raw material. Another
important feature will be a laboratory which provides
analytical services for process control and monitoring
of effluent and environmental samples and pilot scale
testing services to assure satisfactory operation of the
processing plant. The latter normally is not required
in a conventional chemical processing plant, but
because of the highly variable nature of the waste
feed in this case, pilot scale testing is considered
essential.
Hazardous Waste Disposal Facility
For purposes of the model, the hazardous waste
disposal facility will consist of a secure landfill and
the appropriate equipment and structures necessary
to carry out burial and surveillance of the hazardous
solid wastes. Special measures are to be taken during
backfilling to minimize water infiltration. It is possi-
ble that low-level radioactive burial sites currently
used in arid regions of the Western United States
could also be used, with appropriate segregation, for
disposal of the hazardous solid wastes.
Process Selection
Conceptual design objectives for the model facility
included broad treatment capability to permit proc-
essing of all hazardous wastes of significant volume
generated across the country. Important process
selection criteria include demonstrated applicability
to the treatment and disposal of existing hazardous
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78
DISPOSAL OF HAZARDOUS WASTES
wastes and flexibility to handle a wide variety of
different waste streams.
The objectives of waste processing at the model
facility are the removal of hazardous and polluting
substances and/or conversion of these substances to
forms that are acceptable for disposal or reuse. From
the hazardous waste identification portion of this
study described in Section 2 and in Appendix B, it
was determined that in order to accomplish these
objectives the model facility should include treatment
processes for neutralization of acids and bases,
oxidation of cyanides and other reductants, reduction
of chromium-6 and other oxidants, removal of heavy
metals, separation of solids from liquids, removal of
organics, incineration of combustible wastes, removal
of ammonia, and concentration of waste brines.
Treatment processes selected for inclusion in the
model facility were neutralization, precipitation, oxi-
dation and reduction, flocculation and sedimentation,
filtration, ammonia stripping, carbon sorption, incin-
eration, and evaporation. Disposal processes selected
were ocean dumping and landfill. (Appendix D
describes the major characteristics of these processes.)
A conceptual flow diagram, which integrates the
various treatment steps in modular form, was devel-
oped for the model hazardous waste facility (Figure
17). The flow pattern represents that normally
expected and provides for additional piping to permit
alterations when necessary.
Cost Estimates
Design capacities, capital, and operating costs for
typical small-, medium-, and large-size processing
facilities are summarized in Table 16. The costs
include estimates for land, buildings, laboratory
offices, and auxiliary equipment It should be noted
that these cost data are based on preliminary esti-
mates which have been developed from a number of
basic assumptions, and are only intended to indicate
the norm of a range of costs. The following list
identifies in sequence those basic assumptions that
have been utilized to arrive at the number, fixed
capital, and operating costs of large, medium, and
small hazardous waste treatment and disposal
facilities
(1) All hazardous wastes will be treated and
disposed of in an environmentally acceptable manner
INCINERATOR RE3IDUE
Figure 17 Conceptual modular flow diagram.
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SUMMARY OF THE HAZARDOUS WASTE NATIONAL DISPOSAL SITE CONCEPT
79
TABLE 16
PRELIMINARY MODULAR CAPITAL AND OPERATING* COST ESTIMATE SUMMARY FOR SMALL-,
MEDIUM-, AND LARGE-SIZE PROCESSING FACILITIES
Module
Small-size facility:
Aqueous waste treatment' !-
Receiving and storage
Ammonia stripping
Chemical treatment
Liquid/sohas separation
Carbon sorption
Evaporation
Rounded totals
Incineration' A*
Incinerator
Scrubber vvastewater treatment^ I
Rounded total
ium-size facility.
Aqueous waste treatment •'£•>
Receiving and storage
Ammonia stripping
Chemical treatment
Liquid/solids separation
Carbon sorption
Evaporation
Rounded totals
Incineration: § §
Incinerator
Scrubber wastewater treatment' *i
Rounded total
Large-size facility
Aqueous waste treatment. A**
Receiving and storage
Ammonia stripping
Chemical treatment
jiquid/sohds separation
Carbon sorption
Evaporation
Rounded totals
Incineration: ' t '
Incinerator
Scrubber wastewater treatment , -." ::
Rounded total
Fixed
capital cost
(dollars)
1,262,000
296 700
1,827,300
3,460,000
363,000
193,000
7,410,000
1,880,000
3,270,000
773,800
4,734,000
8,963,700
941,000
514,000
19,200,000
4,873,000
11,543,000
2,731,500
16,710,600
30,915,700
3,322,000
3,413,000
68,600,000
17, ''01,700
-
Daily
operating cost
(dollars)
1,881
461
S 3,298
§3,888
§758
§635
10,900
3,200
6,424
952
§11,307
£9.516
*> 1,578
^2,173
32,000
7,000
-
38,150
3,180
§60,630
§34,687
* 6,290
> 15,947
159,000
27,374
-
Average cost
per 1 ,000 gallons'1
(dollars)
6620
18.40
150.50
' 80.10
17 50
14.60
347.00
46.40
7,80
84 70
' 39.60
7.40
10.20
196.00
3360
3.18
53.83
^17.18
3.62
9 16
121 00
Average cost
per ton
(dollars)
213.00
185.00
398 00
94.60
80.60
175.00
45.10
55.70
101.00
*Operation 260 days per year.
13,785 liters.
'iCapacity: 25,000 gallons, (94,600 liters) per day.
§ Includes processing cost for incinerator scrubber wastewater.
1! .eludes processing cost for clarifying incinerator scrubber wastewater.
**Capacity. 15 tons (13.6 metric tons) per day.
'"i'Capacity: 18,450 gallons (70,000 liters) per day.
1 :i Capacity 122,000 gallons (462,000 liters) per day.
§ § Capacity 74 tons (67 metric tons) pei day.
' T Capacity. 90,000 gallons (341,000 liters) per day
A-**Capacity: 1,000,000 gallons (3,785,300 liters) per day.
' ' 'Capacity. 607 tons (550 metric tons) per day.
1 -ft Capacity: 738,000 gallons (2,800,000 liters) per day
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80
DISPOSAL OF HAZARDOUS WASTES
(2) All hazardous wastes will be treated prior to
being disposed of at designated sites to minimize
hazard and volume of wastes deposited on land.
(3) Treatment and disposal facilities will be dedi-
cated to hazardous wastes. Treatment facilities should
have those capabilities indicated in Table 16.
(4) Certain types and quantities of hazardous
wastes will be treated on site (at the source) and
others at off-site facilities. [The estimated total
amount of hazardous wastes to be treated and
disposed of is 1.0 X 10"7 tons (9 X 106 metric tons)
per year. Approximately 4.0 X 10fo tons (3.6 X 10"
metric tons) are inorganic and 6.0 X 106 tons (5.4 X
106 metric tons) are organic.1 ]
(5) EPA economic studies indicate that on-site
treatment facilities will be small plants treating
primarily dilute aqueous acidic toxic metal wastes,
which constitute approximately 15 percent by weight
of all hazardous wastes. Small on-site facilities will be
capable of neutralizing wastes and precipitating toxic
metals from the wastes, but will produce a toxic
residue which will require further treatment at
off-site facilities. Small facilities will have a capacity
of 2.94 X 104 tons (2.6 X 104 metric tons) per year.
Approximately 51 small on-site facilities will be
required to treat the estimated 1.5 X 106 tons (1.36
X 106 metric tons) per year. Approximately one-
third of wastes treated on site [5 X 10'5 tons (4.5 X
10s metric tons) per year| will be shipped to off-site
facilities for further treatment.
(6) To achieve economies of scale, off-site treat-
ment facilities will be large- or medium-size treatment
plants. Approximately 9.0 X 106 tons (8.2 X 106
metric tons) per year will be processed at off-site
facilities. Large facilities will have a capacity of 1.33
X 106 tons (1.2 X 106 metric tons) per year, and
TABLE 17
CAPACITIES AND COSTS OF HAZARDOUS WASTE TREATMENT FACILITIES ASSUMED IN
HAZARDOUS WASTE MANAGEMENT SYSTEM SCENARIO
Item
Capacity:
Aqueous waste processing:
Gallons per day
Liters per day
Tons per day (9 pounds per gallon)
Metric tons per day (9 pounds per gallon)
Combustible waste processing-
Tons per day
Metric tons per day
Total processing:
Tons per day
Metric tons per day
Tons per year
Metric tons per year*
Cost:
Fixed capital (dollars)
Operating:
Dollars per day
Dollars per yeart
With capital writeoff $ (dollars per year)
Approximate number of facilities required §
Total fixed capital costs (million dollars) H
Total operating costs (million dollars per year)**
Large facility
1,000,000
3,800,000
4,500
4,080
607
550
5,107
4,627
1,330,000
1,210,000
86,000,000
186,400
48,500,000
57,100,000
5
430
286
Off site
Medium facility
122,000
462,000
550
498
74
67
624
565
162,000
147,000
24,100,000
39,000
10,130,000
12,540,000
15
362
188
Small facility
25,000
95,000
113
102
15
14
128
116
33,300
30,200
9,300,000
14,100
3,660,000
4,590,000
_
-
—
On site
small facility
25,000
95,000
113
102
—
-
113
102
29,400
26,600
1,400,000
2,265
589,000
729,000
51
71
37
*Assummg actual plant operation of 260 days per year
tlncludes neutralization chemicals, labor, utilities, maintenance, amortization charges (at 7 percent interest), insurance,
taxes, and administrative expenses.
•f 10-year straight line depreciation.
§ Based on data from EPA Contract No. 68-01-0762 and EPA system variation analysis.
HTotal off site and on site, $863 million.
**With capital writeoff, total off site and on site, $511 million per year.
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SUMMARY OF THE HAZARDOUS WASTE NATIONAL DISPOSAL SITE CONCEPT
81
medium facilities a capacity of 1.62 X 10s tons (1 47
X 105 metric tons) per year. System variation studies
indicate that the configuration combining least cost
and adequate geographical distribution consists of 5
large- and 15 medium-size facilities. Therefore, large
off-site treatment facilities will process approximately
6.5 X 106 tons (6.0 X 106 metric tons) per year and
medium facilities will process approximately 2.5 X
106 tons (2.27 X 106 metric tons) per year.
(7) Current treatment technology does not allow
complete neutralization/detoxification of all
hazardous wastes. It is estimated that treatment
residues constituting 2.5 percent of the incoming
waste [225,000 tons (200,000 metric tons) per year]
will still be hazardous.1 Hazardous residues resulting
from treatment facilities will be disposed of in secure
land disposal sites. The most convenient location for
secure land disposal sites is in association with the
large treatment facilities. Therefore, five large secure
disposal sites would initially be required. Hazardous
wastes generated at other off-site treatment facilities
would also be disposed of at these sites.
This information was then utilized to develop the
configuration for the scenario of a hazardous waste
management system cited in Section 4
A more detailed comparative cost analysis that
identifies and summarizes capacities, fixed capital,
and operating costs associated specifically with treat-
ment facilities has been developed in Table 17. These
data were utilized in developing the cost aspects of
the system scenario.
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Appendix G
PROPOSED
Hazardous
Waste
Management
Act
of 1973
93d Congress,
1st Session
IN THE U.S. SENATE
Bill S. 1086
Introduced by Senator Baker
March 6, 1973
Referred to Committee on Public Works
IN THE U.S. HOUSE OF REPRESENTATIVES
Bill H.R. 4873
Introduced by Representative Staggers
for himself
and Representative Devine
February 27, 1973
Referred to Committee
on Interstate and Foreign Commerce
83
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84 DISPOSAL OF HAZARDOUS WASTES
A BILL
To assure protection of public health and other living organisms
from the adverse impact of the disposal of hazardous wastes,
to authorize a research program with respect to hazardous
waste disposal, and for other purposes.
1 Be it enacted by the Senate and House of Representa-
2 lives of the United States of America in Congress assembled,
3 SECTION 1. This Act may be cited as the "Hazardous
4 Waste Management Act of 1973".
5 FINDINGS AND PURPOSE
6 SEC. 2. (a) The Congress finds—
7 (1) that continuing technological progress, 5m-
8 provement in the methods of manufacture, and abate-
-------
PROPOSED HAZARDOUS WASTE MANAGEMENT ACT OF 1973 85
1 ment of air and water pollution has resulted in an
2 ever-mounting increase of hazardous wastes;
3 (2) that improper land disposal and other manage-
4 ment practices of solid, liquid, and semisolid hazardous
5 wastes which are a part of interstate1 commerce are re-
6 suiting in adverse impact on health and oilier living or-
7 ganisms ;
8 (3) that the knowledge and technology necessary
9 for alleviating adverse health, environmental, and es-
10 thetic impacts associated with current waste manage-
11 ment and disposal practices are generally available at
12 costs within the financial capacity of those who generate
13 such wastes, even though this knowledge and technology
14 are not widely utilized;
15 (4) that private industry has demonstrated its
16 capacity and willingness to develop, finance, construct,
37 and operate facilities and to perform other activities for
18 the adequate disposal of hazardous and other waste
19 materials;
20 (5) that while the collection and disposal of wastes
21 should continue to be a responsibility of private individ-
22 uals and organizations and the concern of State, regional,
23 and local agencies, the problems of hazardous waste
24 disposal as set forth above and as an intrinsic part of
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86 DISPCrAL OF HAZARDOUS WASTES
1 interstate commerce have become a matter national in
2 scope and in concern, and necessitate Federal action
3 through regulation of the treatment and the disposal of
4 the most hazardous of these wastes, and through techni-
5 cal and other assistance in the application of new and
6 improved methods and processes to provide for proper
7 waste disposal practices and reductions in the amount of
8 waste and unsalvageahle materials.
9 (b) The purposes of this Act therefore are—
10 (1) to protect public health and other living orga-
11 nisms (through Federal regulation in the treatment and
12 disposal of certain hazardous wastes;
13 (2) to provide for the promulgation of Federal
14 guidelines for State regulation of the treatment and
15 disposal of hazardous wastes not subject to Federal reg-
16 ulation;
17 (3) to provide technical and other assistance to
18 public and private institutions in the application of ef-
19 ficient and effective waste management systems;
20 (4) to promote a national research program relat-
21 ing to the health and other effects of hazardous wastes
22 and the prevention of adverse impacts relating to health
23 and other living organisms.
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PROPOSED HAZARDOUS WASTE MANAGEMENT ACT OF 1973 87
1 DEFINITIONS
2 SEC. 3. When used in this Act:
3 (1) The term "Administrator" means the Administra-
4 tor of the Environmental Protection Agency.
5 (2) The term "State" means a State, the District of
6 Columbia, and the Commonwealth of Puerto Rico.
7 (3) The term "waste" means useless, unwanted, or
8 discarded solid, semisolid or liquid materials.
9 (4) The term "hazardous \vaste" means any waste or
10 combination of wastes which pose a substantial present or
11 potential hazard to human health or living organisms because
12 such wastes are nondegradable or persistent in nature or
13 because they can be biologically magnified, or because they
14 can be lethal, or because they may otherwise cause or tend
15 to cause detrimental cumulative effects.
16 (5) The term "secondary material" means a material
17 that is or can lie utilized in place of a primary or raw
18 material in manufacturing a product.
19 (6) The term "generation" means the act or process
20 of producing waste materials.
21 (7) The term "storage" means the interim contain-
22 ment of waste after generation and prior to ultimate disposal.
23 Containment for more than two years shall be considered
24 disposal.
25 (8) The term "transport" means the movement of
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88 DISPOSAL OF HAZARDOUS WASTES
1 wastes from the point of generation to any intermediate
2 transfer points, and finally to the point of ultimate dis-
3 posal.
4 (9) The term "treatment" means any activity or proc-
5 cssing designed to change the physical form or chemical
6 composition of waste so as to render such materials non-
7 hazardous.
8 (10) The term "disposal of waste" means the dis-
9 charge, deposit, or injection into subsurface strata or exca-
10 vations or the ultimate disposition onto the land of any
11 waste.
12 (11) The term "disposal site" means the location where
13 any final deposition of waste materials occurs.
14 (12) The term "treatment facility" means a location
15 at which waste is subjected to treatment and may include
16 a facility where waste has been generated.
17 (13) The term "person" means any individual, partner-
18 ship, copartnership, firm, company, corporation, association.
19 joint stock company, trust, State, municipality, or any legal
20 representative agent or assigns.
21 (14) The term "municipality" means a city, town,
22 borough, county, parish, district, or other public body created
23 by or pursuant to State law with responsibility for the plan-
24 ning or administration of waste management, or an Indian
2$ tribe or an authorized Indian tribal organization.
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PROPOSED HAZARDOUS WASTE MANAGEMENT ACT OF 1973 89
1 (15) The term "waste management" means the sys-
2 tematic control of the generation, storage, transport, treat-
3 ment, recycling, recovery, or disposal of waste materials.
4 STANDARDS AND GUIDKLINKS FOR STATK KI'XH'LATIOX
5 SEC. 4. (a) Within eighteen months after the date of
6 enactment of this Act, and from tame to time thereafter, the
7 Administrator pursuant to this section and after consultation
8 with representatives of appropriate Federal agencies shall by
9 regulation—
10 (1) identify hazardous wastes;
11 (2) establish standards for treatment arid disposal
12 of such wastes; and
13 (3) establish guidelines for State programs for im-
14 plementing such standards.
15 (b) In identifying a waste as hazardous, pursuant to
16 this section, the Administrator shall specify quantity, con-
17 centration, and the physical, chemical, or biological proper-
18 ties of such waste, taking into account means of disposal,
19 disposal sites, and available disposal practices.
20 (c) The standards established under this section shall
21 include minimum standards of performance required to pro-
22 tect human health and other living organisms and minimum
23 acceptable criteria as to characteristics and conditions of dis-
24 posal sites and operating methods, techniques, and practices
25 of hazardous wastes disposal taking into account the nature
-------
90 DISPOSAL OF HAZARDOUS WASTES
1 of the hazardous waste to be disposed. Such standards shall
2 include but not be limited to requirements that any person
3 generating waste must (1) appropriately label all containers
4 used for onsite storage or for transport of hazardous
5 waste; (2) follow appropriate procedures for treating haz-
6 ardous waste onsite; (3) transport all hazardous waste
7 intended for offsite disposal to a hazardous waste disposal
8 facility for which a permit has been issued. In establishing
9 such standards the Administrator shall take into account
10 the economic and social costs and benefits of achieving such
11 standards.
12 (d) The guidelines established under paragraph (a) (3)
13 of this section shall provide that—
14 (1) with respect to disposal sites for hazardous
15 wastes, the State program requires that any person
16 obtain from the State a permit to operate such site;
1^ (2) such permits require compliance with the
18 minimum standards of performance acceptable site cri-
19 teria set by the guidelines;
20 (3) the State have such regulatory and other au-
21 thorities as may be necessary to carry out the purpose
22 of this Act, including, but not limited to, the authority
23 to inspect disposal sites and records, and to judicially
24 enforce compliance with the requirements of an ap-
25 proved program against any person.
-------
PROPOSED HAZARDOUS WASTE MANAGEMENT ACT OF 1973 91
1 (e) Within eighteen months of the promulgation of
2 final regulations under this Act, each State shall submit to
3 the Administrator evidence, in such form as he shall re-
4 quire, that the State has established a State program which
5 meets the requirement of the guide-lines of paragraph (a)
6 (3) of this section. If a State fails to submit such evidence,
7 in whole or in part, the Administrator shall publish notice
8 of such failure in the Federal Register and provide such
9 further notification, in such form as he considers appropriate,
10 to inform the public in such State of such failure.
11 FEDEEAL REGULATION
12 SEC. 5. (a) Within eighteen months after the date of
13 enactment of this Act and from time to time thereafter, the
14 Administrator after consultation with representatives of
15 appropriate Federal agencies may with respect to those
16 hazardous wastes identified pursuant to subsection (a) (1)
I? of section 4 determine in regulations those of such wastes
18 which because of their quantity or concentration, or because
19 of their chemical characteristics, could if allowed to be dis-
20 persed into the environment result in, or contribute to, the
21 loss of human life or substantial damage to human health
22 or to other living organisms.
23 (b) The Administrator may promulgate regulations
24 establishing Federal standards and procedures for the
25 treatment and disposal of such wastes. Such Federal stand-
-------
92 DISPOSAL OF HAZARDOUS WASTES
1 ards and procedures shall be designed to prevent damage
2 to human health or living organisms from exposure to such
3 wastes identified pursuant to subsection (a) and may
4 include—
5 (1) with respect to hazardous waste disposal
6 sites—
7 (A) minimum requirements as to the char-
ts acteristics and conditions of such sites,
9 (B) minimum standards of performance for
10 the operation and maintenance of such sites, and
11 (C) recommendations as to specific design and
12 construction criteria for such sites; and
13 (2) with respect to hazardous waste treatment
14 facilities—
15 (A) minimum standards of performance for
16 the operation and maintenance, and
1^ (B) recommendations based on available tech-
18 nology as to appropriate methods, techniques, or
19 practices for the treatment of specific wastes.
20 (c) The Administrator may issue a permit for the
21 operation of a hazardous waste disposal site or treatment
22 facility if, after a review of the design, construction, and
23 proposed operation of such site or facility, he determines
24 that such operation will meet the requirements and standards
25 promulgated pursuant to subsection (b).
-------
PROPOSED HAZARDOUS WASTE MANAGEMENT ACT OF 1973 93
I (d) Within eighteen mouths after the date of enactment
2 of this Act, the Administrator shall promulgate regulations
3 establishing requirements for generators of hazardous wastes
4 subject to regulation under this section to—
5 (1) maintain records indicating the quantities of
y hazardous waste generated and the disposition thereof;
7 (2) package hazardous waste in such a manner so
8 as to protect human health and other living organisms,
9 and label such packaging so as to identify accurately
10 such wastes;
11 (3) treat or dispose of all hazardous waste at a
12 hazardous waste disposal site or treatment facility for
13 which a permit has been issued under this Act;
14 (4) handle and store all hazardous waste in such a
15 manner so as not to pose a threat to human health or
16 other living organisms;
17 (5) submit reports to the Administrator, at such
18 times as the Administrator deems necessary, setting
19 out—
20 (A) the quantities of hazardous waste subject
21 to Federal regulation under this subsection that he
22 has generated;
23 (B) the nature and quantity of any other waste
24 which he has generated which he has reason to be-
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94 DISPOSAL OF HAZARDOUS WASTES
1 lieve may have a substantial adverse effect on
2 human health and other living organisms; and
3 (C) the disposition of all waste included in
4 categories (A) and (B).
5 (e) The Administrator may prescribe regulations re-
6 quiring any person who stores, treats, disposes of, or other-
7 wise handles hazardous wastes subject to regulation under
8 this section to maintain such records with respect to their
9 operations as the Administrator determines are necessary
10 for the effective enforcement of this Act.
11 (f) The Administrator is authorized to enter into coop-
12 erative agreements with States to delegate to any State
13 which meets such minimum requirements as the Administra-
14 tor may establish by regulation the authority to enforce this
15 section against any person.
I6 FEDERAL ENFORCEMENT
17 SEC. 6. (a) Whenever on the basis of any information
18 the Administrator determines that any person is in violation
19 of requirements under section 5 or of any standard under
20 section 4 (a) (2) under this Act, the Administrator may
21 give notice to the violator of his failure to comply with such
22 requirements or may request the Attorney General to com-
23 mence a civil action in the appropriate United States district
24 court for appropriate relief, including temporary or perma-
25 nent injunctive relief. If such violation extends beyond the
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PROPOSED HAZARDOUS WASTE MANAGEMENT ACT OF 1973 95
1 thirtieth day after the Administrator's notification, the Ad-
2 ministrator may issue an order requiring compliance within
3 a specified time period or the Administrator may request
4 the Attorney General to commence a civil action in the
5 United States district court in the district, in which the vio-
6 lation occurred for appropriate relief, including a temporary
7 or permanent injunction: Provided, That, in the case of a
8 violation of any standard under section 4 (a) (2) where such
9 violation occurs in a State which has submitted the evidence
10 required under section 4(e), the Administrator shall give
11 notice to the State in which such violation has occurred
12 thirty days prior to issuing an order or requesting the Attor-
13 ney General to commence a civil action. If such violator fails
14 to take corrective action within the time specified in the
15 order, he shall be liable for a civil penalty of not more than
16 825,000 for each day of continued noncompliance. The
17 Administrator may suspend or revoke any permit issued to
18 the violator.
19 (b) Any order or any suspension or revocation of a
20 permit shall become final unless, no later than 30 days after
21 the order or notice of the suspension or revocation is served,
22 the person or persons named therein request a public hear-
23 ing. Upon such request the Administrator shall promptly
24 conduct a public hearing. In connection with any proceed-
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96 DISPOSAL OF HAZARDOUS WASTES
1 ing under this section the Administrator may issue subpenas
2 for the attendance and testimony of witnesses and the produc-
3 tion of relevant papers, books, and documents, and may
4 promulgate rules for discovery procedures.
5 (c) Any order issued under this section shall state with
6 reasonable specificity the nature of the violation and specify
7 a time for compliance and assess a penalty, if any, which the
8 Administrator determines is a reasonable period and penalty
9 taking into account the seriousness of the violation and any
10 good faith efforts to comply with the applicable requirements.
11 (d) Any person who knowingly violates any require-
12 ment of this Act or commits any prohibited act shall, upon
13 conviction, be subject to a fine of not more than $25,000
14 for each day of violation, or to imprisonment not to exceed
15 one year, or both.
16 RESEARCH, DEVELOPMENT, INVESTIGATIONS, TECHNICAL
17 ASSISTANCE AND OTHER ACTIVITIES
18 SEC. 7. (a) The Administrator shall conduct, encour-
19 age, cooperate with, and render financial and other assist-
20 ance to appropriate public (whether Federal, State, inter-
21 state, or local) authorities, agencies, and institutions, private
22 agencies and institutions, and individuals in the conduct of,
23 and promote the coordination of, research, development, in-
24 vestigations, experiments, surveys, and studies relating to—
-------
PROPOSED HAZARDOUS WASTE MANAGEMENT ACT OF 1973 97
1 (1) any adverse health and welfare effects on the
2 release into the environment of material present in
3 waste, and methods to eliminate such effects;
4 (2) the operation or financing of waste manage-
5 ment programs;
6 (3) the development and application of new and
7 improved methods of collecting and disposing of waste
8 and processing and recovering materials and energy
9 from wastes; and
10 (4) the reduction of waste generation and the re-
11 covery of secondary materials and energy from solid,
12 liquid, and semi solid wastes.
13 (b) In carrying out the provisions of the preceding
14 subsection, the Administrator is authorized to—
15 (1) collect and make available, through publica-
lt> tion and other appropriate means, the results of, and
17 other information pertaining to, such research and other
18 activities, including appropriate recommendations in
19 connection therewith;
20 (2) cooperate with public and private agencies,
21 institutions, and organizations, and with any industries
22 involved, in the preparation and the conduct of such rc-
23 search and other activities; and
24 (3j make grants-in-aid to and contract with public
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98 DISPOSAL OF HAZARDOUS WASTES
1 or private agencies and institutions and individuals for
2 research, surveys, development, and public education.
3 Contracts may be entered into without regard to sections
4 3648 and 3709 of the Revised Statutes (31 U.S.C. 529;
5 41 U.S.C. 5).
6 (c) The Interstate Commerce Commission, the Federal
7 Maritime Commission, and the Office of Oil and Gas in the
8 Department of the Interior, in consultation with the Environ-
9 mental Protection Agency and with other Federal agencies
10 as appropriate, shah1 conduct within twelve months of the
11 date of enactment of this Act and submit to Congress, a
12 thorough and complete study of rate setting practices with
13 regard to the carriage of secondary materials by rail and
14 ocean carriers. Such study shall include a comparison of
15 such practices with rate setting practices with regard to
16 other materials and shah1 examine the extent to which, if at
17 all, there is discrimination against secondary materials.
18 INSPECTIONS
19 SEC. 8. (a) For the purpose of developing or assisting
20 in the development of any regulation or enforcing the
21 provisions of this Act, any person who stores, treats, trans-
22 ports, disposes of, or otherwise handles hazardous wastes
23 shall, upon request of any officer or employee of the Environ-
24 mental Protection Agency or of any State or political sub-
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PROPOSED HAZARDOUS WASTE MANAGEMENT ACT OF 1973 99
1 division, duly designated by the Administrator, furnish or
2 permit such person at all reasonable times to have access to,
3 and to copy all records relating to such wastes.
4 (b) For the purposes of developing or assisting in the
5 development of any regulation or enforcing the provisions
6 of tins Act, officers or employees duly designated by the
7 Administrator are authorized—
8 (1) to enter at reasonable times any establish-
9 inent or other place maintained by any person where
10 ha/ardous wastes are stored, treated, or disposed of;
11 (2) to inspect and obtain samples from any person
12 of any such wastes and samples of any containers or
13 labeling for such wastes. Before undertaking such in-
14 spection, the officers or employees must present to the
15 owner, operator, or agent in charge of the establishment
16 or other place where hazardous wastes are stored,
17 treated, or disposed of appropriate credentials and a
18 written statement as to the reason for the inspection.
19 Each such inspection shall be commenced and completed
20 with reasonable promptness. If the officer or employee
21 obtains any samples, prior to leaving the premises, he
22 shall give to the owner, operator, or agent in charge
23 a receipt describing the sample obtained and if requested
24 a portion of each such sample equal in volume or weight.
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100 DISPOSAL OF HAZARDOUS WASTES
1 to the portion retained. If an analysis is made of such
2 samples, a copy of the results of such analysis shall be
3 furnished promptly to the owner, operator, or agent
4 in charge.
5 (c) Any records, reports, or information obtained from
6 any person under this subsection shall be available to the
7 public, except that upon a showing satisfactory to the Ad-
8 ministrator by any person that records, reports, or informa-
9 tion, or particular part thereof, to which the Administrator
10 has access under this section if made public, would divulge
11 information entitled to protection under section 1905 of
12 title 18 of the United States Code, the Administrator shall
13 consider such information or particular portion thereof con-
1-1 fidential in accordance within the purposes of that section.
15 ENCOURAGEMENT OF INTERSTATE AND INTERLOCAL
16 COOPERATION
17 SBC. 9. The Administrator shall encourage cooperative
18 activities by the States and local governments in connection
19 with waste disposal programs, encourage, where practicable,
20 interstate, interlocal, and regional planning for, and the
21 conduct of, interstate, interlocal, and regional hazardous
22 waste disposal programs; and encourage the enactment of
23 improved and, so far as practicable, uniform State and local
24 laws governing waste disposal.
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PROPOSED HAZARDOUS WASTE MANAGEMENT ACT OF 1973 101
1 IMMINENT HAZARD
2 SEC. 10. (a) An imminent hazard shall be considered to
3 exist when the Administrator has reason to believe that
4 handling or storage of a hazardous waste presents an im-
5 minent and substantial danger to human health or other liv-
6 ing organisms the continued operation of a disposal site will
7 result in such danger when a State or local authority has
8 not acted to eliminate such risk.
9 (b) If an imminent hazard exists, the Administrator
10 may request the Attorney General to petition the district
11 court of the United States in the district where such hazard
12 exists, to order any disposal site operator or other person
13 having custody of such waste to take such action as is neces-
14 sary to eliminate the imminent hazard, including, but not
15 limited to, permanent or temporary cessation of operation of
16 a disposal site, or such other remedial measures as the court
17 deems appropriate.
18 PEOHIBITED ACTS
19 SEC. 11. The following acts and the causing thereof are
20 prohibited and shall be subject to enforcement in accord-
21 ance with the provisions of subsection 6(d) of this Act:
22 (a) Operating any disposal site for hazardous waste
23 identified pursuant to section 5 without having obtained an
24 operating permit pursuant to such section.
25 (b) Disposing of hazardous waste identified pursuant
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102 DISPOSAL OF HAZARDOUS WASTES
1 to section 5 in a manner not in compliance with requirements
2 under section 5.
3 (c) Failure to comply with the requirements of section 5
4 in labeling containers used for the storage, transport, or dis-
5 posal of hazardous waste.
6 (d) Failure to comply with (1) the conditions of any
7 Federal permit issued under this Act, (2) any regulation
8 promulgated by the Administrator pursuant to section 4 (a)
9 (2) or section 5 of this Act, or (3) any order issued by the
10 Administrator pursuant to this Act.
11 APPLICATION OF STANDAEDS TO FEDERAL AGENCIES
12 SEC. 12. (a) Each department, agency, and instramen-
13 tality of the executive, legislative, and judicial branches of
14 the Federal Government having jurisdiction over any prop-
15 erty or facility, or engaged in any activity which generates,
16 or which may generate, wastes shall insure compliance with
17 such standards pursuant to subsections 4(a) (2), 5(a), and
18 5 (c) as may be established by the Administrator for the
19 treatment and disposal of such wastes.
20 (b) The President or his designee may exempt any
21 facility or activity of any department, agency, or instrumen-
22 tality in the executive branch from compliance with guide-
23 lines established under section 4 if he determines it to be in
24 the paramount interest of the United States to do so. Any
25 exemption shall be for a period not in excess of one year,
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PROPOSED HAZARDOUS WASTE MANAGEMENT ACT OF 1973 103
1 but additional exemptions may be granted for periods of not
2 to exceed one year upon the President's or his designee's
3 making of a new determination. The Administrator shall
4 ascertain the exemptions granted under this subsection and
5 shall report each January to the Congress all exemptions
6 from the requirements of this section granted during the pre-
7 ceding calendar year.
8 (c) Within eighteen months after enactment of this Act
9 and from time to time thereafter, the Administrator, in con-
10 sultation with other appropriate Federal agencies, shall
11 identify products which can utilize significant quantities of
12 secondary materials and shall issue guidelines with respect
13 to the inclusion of such secondary materials to the maximum
34 extent practicable in products procured by the Federal
15 Government.
16 (d) In any proceeding initiated before the Interstate
17 Commerce Commission or the Federal Maritime Commis-
18 sion after the enactment of this Act where a determination
19 is made by such Commission as to any individual or joint
20 rate, fare, or charge whatsoever demanded, charged, or
21 collected by any common carrier or carriers, a specific find-
22 ing by the Commission will be required that such rate, fare,
23 or charge does not or will not cause discrimination against
24 secondary materials.
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104 DISPOSAL OF HAZARDOUS WASTES
1 CITIZEN SUITS
2 SEC. 13. (a) Except as provided in subsection (b) any
3 person may commence a civil action for injunctive relief on
4 his own behalf—
5 (1) against any person who is alleged to be in
6 violation of any regulation promulgated or order issued
7 under this Act;
8 (2) against the Administrator where there is al-
9 leged a failure of the Administrator to perform any act
10 or duty under this Act which is not discretionary with
11 the Administrator.
12 Any action under paragraph (a) (1) of this subsection
13 shall be brought in the district court for the district in which
34 the alleged violation occurred and any action brought under
15 paragraph (a) (2) of this subsection shall be brought in
16 the District Court of the District of Columbia. The district
17 courts shall have jurisdiction, without regard to the amount
18 in controversy or the citizenship of the parties, to enforce
19 such regulation or order, or to order the Administrator to
20 perform such act or duty as the case may be.
21 (b) No action may be commenced—
22 (1) under subsection (a) (1) of this section—
23 (A) prior to sixty days after the plaintiff has
24 given notice of the violation (i) to the Adminis-
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PROPOSED HAZARDOUS WASTE MANAGEMENT ACT OF 1973 105
1 trator, (ii) to the State in which the alleged viola-
2 tion occurs, and (in) to any alleged violator of the
!! standard, limitation, or order, or
4 (B) if the Administrator or State has caused to
5 be commenced and is diligently prosecuting a civil
(5 or criminal action in a court of the United States
7 or a State to require compliance with requirements
8 of this Act or order issued hereunder;
9 (2) under subsection (a) (2) prior to sixty days
10 after plaintiff has given notice of such action to the
11 Administrator.
12 Notice under this subsection shall be given in
13 such manner as the Administrator shall prescribe by
14 regulation.
15 (3) in such action under this section, if the United
16 States is not a party, the Attorney General may inter-
17 vene as a matter of right.
18 (d) The court, in issuing any final order in any action
19 brought pursuant to this section, may award costs of litiga-
20 tion (including reasonable attorney and expert witness fees)
21 to any party, whenever the court determines such award is
22 appropriate.
23 (e) Nothing in this section shall restrict any right
24 which any person (or class of persons) may have under any
25 statute or common law to seek enforcement of any regulation
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106 DISPOSAL OF HAZARDOUS WASTES
1 or to seek any other relief (including relief against the Ad-
2 mmistrator or a State agency).
3 STATE AUTHORITY
4 SEC. 14. (a) If the Administrator has promulgated
5 regulations under section 5 no State or municipality may
6 without the approval of the Administrator impose more
7 stringent requirements than those imposed under the pro-
8 visions of section 5 on the transport, treatment, or disposal
9 of hazardous wastes.
10 (b) No State or municipality shall impose, on wastes
11 originating in other States or municipalities, requirements re-
12 specting the transport of such wastes into or disposal within
13 its jurisdiction which are more stringent than those require-
14 ments applicable to wastes originating within such receiving
15 States and municipalities.
16 AUTHORIZATION AND APPROPRIATION
17 SEC. 15. There is hereby authorized to be appropriated
18 to the Environmental Protection Agency such sums as may
19 be necessary for the purposes and administration of this Act.
20 JUDICIAL REVIEW
21 SEC. 16. (a) A petition for review of action of the Ad-
22 ministrator in promulgating any regulation pursuant to sec-
23 tions 4 or 5 shall be filed in the United States Court of Ap-
24 peals for the District of Columbia. Any person who will be
25 adversely affected by a final order or other final determina~
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PROPOSED HAZARDOUS WASTE MANAGEMENT ACT OF 1973 107
1 tion issued under section 6 may file a petition with the
2 United States Court of Appeals for the circuit wherein such
3 person resides or has his principal place of business, for a
4 judicial review of such order or determination. Any such
5 petition shall be filed within thirty days from the date of such
6 action or order, or after such date if such petition is based
7 solely on grounds arising after such thirtieth day.
8 (b) Action of the Administrator with respect to which
9 review could have been obtained under subsection (a) shall
10 not be subject to judicial review in civil or criminal proceed-
11 ings for enforcement.
12 (c) In any judicial proceeding in which review is
13 sought of an action under this Act required to be made on
14 the record after notice and opportunity for hearing, if any
15 party applies to the court for leave to adduce additional
16 evidence, and shows to the satisfaction of the court that such
17 additional evidence is material and that there were reason-
18 able grounds for the failure to adduce such evidence in the
19 proceedings before the Administrator, the court may order
20 such additional evidence (and evidence in rebuttal thereof)
21 to be taken before the Administrator, in such manner and
22 upon such terms and conditions as the court may deem
23 proper. The Administrator may modify his findings as to
24 the facts, or make new findings, by reason of the additional
25 evidence so taken and he shall file such modified or new
-------
108 DISPOSAL OF HAZARDOUS WASTES
1 findings, and his recommendation, if any, for the modifica-
2 tion or setting aside of his original determination, with the
3 return of such additional evidence.
4 RELATIONSHIP TO OTHER LAWS
5 SEC. 17. (a) This Act shall not apply to—
6 (1) any source material, special nuclear material,
7 or byproduct material subject to regulation or control
8 pursuant to the Atomic Energy Act of 1954, as
9 amended ;
10 (2) lethal chemicals subject to regulation pur-
11 suant to title 50, United States Code, section 1511,
12 and the following, as amended.
13 (b) This Act shall riot be construed to relieve any
14 person from any present or future requirement arising from
15 any other Federal law.
-------
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